Privacy Policy | Sollers

Information related to Data protection

Personal Data Processing Policy

Introduction

At Sollers Holding Spółka z ograniczoną odpowiedzialnością with its registered office in Warsaw, address: Warsaw (00-675), 54 Koszykowa St., entered into the register of entrepreneurs maintained by the National Court Register for the capital city of Warsaw, 12th Commercial Division of the National Court Register, under the number KRS 0000738636 (the “Controller”), we are strongly committed to protecting personal data and keeping everyone informed in an open and transparent way. Personal data is processed for numerous purposes. For each purpose the way how data is collected, used, disclosed, as well as our lawful basis for its processing, and the retention periods may differ. By reading this Privacy Policy you will learn more about the details on the collection and use of your personal data as well as what your individual rights are. To find out more about our specific processing activities, please go to the relevant sections of this Policy.

Sollers Holding Sp. z o.o. is the owner of the website www.sollers.eu and provides the companies of Sollers Group with a place on the website (hosting).

Sollers Consulting Sp. z o.o. maintains and provides the companies of Sollers Group with the IT system in which personal data is processed for another company from the group that is the data administrator. The IT system meets the requirements of the data Controller’s and controllers’ countries. However, companies in the can provide information to each other in accordance with the requirements set out in the contracts entrusting the processing of personal data and in accordance with the applicable laws. Personal data must be processed and collected in accordance with the GDPR and national provisions regarding personal data. In the scope of personal data collected and processed by the companies of Sollers Group, each of these companies becomes the controller of personal data. Therefore, for the data submitted for processing by:

Sollers Consulting Spółka z ograniczoną odpowiedzialnością with its registered office in Warsaw, address: Warsaw (00-675), 54 Koszykowa St., entered into the register of entrepreneurs maintained by the National Court Register for the capital city of Warsaw, 12th Commercial Division of the National Court Register, under the number KRS 0000191247, the controller of personal data will be Sollers Consulting Sp. z o.o.
Sollers Consulting GmbH (incorporated under German law), with its registered office in Cologne, Germany, Cäcilienstraße 30, 50667 Cologne, registered under the Handelsregister Amtsgericht Cologne under number HRB 83628, the controller of personal data will be Sollers Consulting GmbH
Sollers Consulting K.K., based in TSR, Bldg. 3F 20-9 Nishishimbashi 1- chome Minato ku, Tokyo, Japan, number: 0100-01-192224, the controller of personal data will be Sollers Consulting K.K.
Sollers Consulting (Société par actions simplifiée; SAS) with its registered office in Paris and address: 22 rue des Capucines, 75002 Paris, entered into the Registre du Commerce et des Societes, under RCS number: 888 208 097, number SIREN: 888 208 097, number SIRET: 888 208 097 00020, the controller of personal data will be Sollers Consulting SAS.
Sollers Consulting LLC (Limited liability company under the law of Delaware), based in Richmond, VA and address: 1806 Summit Ave, Suite 300 #1072, Richmond, VA 23230, registered by The Secretary of State of Delaware with Corporation Number – 6602341 and Authentication _number – 202723053, the controller of personal data will be Sollers Consulting LLC.
Sollers Consulting Information Technology SL (Sociedad Limitada) with its registered office in Valencia, Spain and address: 46021-Valencia, Avenida de Aragón, número 30, 8ª planta, oficina 846, entered into Registro Mercantil, under NIF number: B10970788, the controller of personal data will be Sollers Consulting Information Technology SL.
Sollers Consulting Sdn. Bhd. with its registered office in Kuala Lumpur, Malaysia and address: in Unit 37-2, Level 37, Q Sentral, No. 2A, Jalan Stesen Sentral 2, Kuala Lumpur Sentral 50470, entered into Registrar of Companies under Company registration number: 202301011497 (1505419-T), the controller of personal data (data user) will be Sollers Consulting Sdn. Bhd.
Sollers Consulting Information Technology Ltd. with its registered office in London, United Kingdom and registered address: 203 London Road Hadleigh Benfleet SS7 2RD into Companies House under the Company number 14846071, having Tax Office number 623, UTR number 45692 20510 and VAT number GB447990151, and business address: 14 Cullum Street, London, United Kingdom, EC3M 7JJ, the controller of personal data will be Sollers Consulting Information Technology Ltd.

Therefore, all provisions applicable to Sollers Holding apply accordingly to individual companies of the Sollers Group acting as controllers in the scope of data collected and processed by these companies. In this case, the Controller definition should be applied accordingly.

What is personal data?

Personal data is any information relating to an identified or identifiable living person.

What personal data does the Policy cover?

In this , "personal data" means information about a natural person who can be directly or indirectly identified, in particular based on an identifier such as a name, an identification number, location data or an online identifier. Personal data also refers to one or more specific factors determining the physical, physiological, genetic, mental, economic, cultural or social identity of a natural person.

What are the legal grounds for processing data?

Legal grounds for processing personal data visiting our website:

The pursuit of a legitimate interest in developing and improving our website, providing users with tailored content.

Legal grounds for processing the personal data of our clients or of natural persons whose personal data we obtain in connection with providing services to our clients:

Compliance with legal or regulatory obligations.
Performance of the contract.

Legal grounds for processing the personal data of natural persons appearing in our contact database:

Explicit consent of a natural person appearing in the commercial contacts database.
The pursuit of a legitimate interest in managing relationships with individuals in a database of business contacts and providing information on Sollers, our services and events organised by us.

Legal grounds for processing the personal data of event participants:

Participant's explicit consent.
Realisation of a legitimate interest in organizing events and managing the registration process of participants for such events.
The pursuit of a legitimate interest to protect our employees, property and information, and to prevent unauthorized access to Sollers events taking place outside of the company.

Legal grounds for the processing of personal data of individuals visiting our pages on social media and the use of social media plug-ins and tools:

The pursuit of a legitimate interest in promoting the Sollers brand and services.
Realization of a legitimate interest in attracting, identifying and recruiting highly qualified employees.
The pursuit of a legitimate interest in improving the experience of individuals visiting our website and optimizing our services.

Legal grounds for processing personal data of Sollers alumni:

Sollers hopes to maintain long-term and mutually beneficial relations with Sollers alumni. In the event of an invitation to our alumni community, to enter the invited person into one of our alumni databases, data such as name and surname, contact details: email and telephone number will be used, unless the invited person states that they are not interested participation in the Sollers alumni program. Each alumnus/alumna has the possibility to create a more detailed profile and decide on the scope of information that Sollers wants to share with the wider alumni community.

Clear consent of the alumni
Realizing a legitimate interest in maintaining a strong relationship with Sollers alumni, sending publications on Sollers and our services, inviting alumni to our events, and helping alumni to keep in touch with other Sollers alumni.

Legal grounds for processing personal data of individuals conducting e-mail correspondence with Sollers:

The pursuit of a legitimate interest in securing our IT infrastructure against unauthorized access and data leakage.
Realization of a legitimate interest in analyzing mail traffic statistics e-mail.

Legal grounds for processing personal data of natural persons applying for a job at Sollers:

Clear consent from the candidate.
Realization of a legitimate interest in carrying out the recruitment process, including attracting, identifying, verifying, sourcing talent and recruiting employees.
Realization of a legitimate interest to process and manage application for roles at Sollers, including the screening and selecting.
Realization of a legitimate interest to hire and onboard candidates by making an offer to successful candidates, and carrying out pre-employment screening checks.
Realization of a legitimate interest to manage Sollers career websites (including conducting statistical analyses).
Compliance with a legal or regulatory obligation (when carrying out background checks to warrant a candidate is eligible to work).

Legal grounds for processing personal data of our suppliers:

Performance of the contract.
Compliance with legal or regulatory obligations.

Legal grounds for processing personal data of natural persons visiting the Sollers offices:

The pursuit of a legitimate interest in protecting Sollers' offices, staff, goods and confidential information.
The pursuit of a legitimate interest in preventing and detecting crimes and establishing, investigating and defending claims.

Social media - plugins, description.

Sollers uses various social platforms, including for recruitment purposes and marketing. We use social media to provide Internet users with easy access to relevant information about jobs at Sollers and the opportunity to participate in our events, as well as to promote our services and brand.

Sollers is responsible for content published via social media platforms, but is not responsible for managing such platforms (creating user statistics and placing cookies). When using social platforms, users are required to comply with legal requirements and privacy conditions imposed by providers of such social media. Suppliers collect users' personal data, including statistical and analytical data on the use of social platforms, including information on websites viewed, likes, recent visits and entries that have been published by the user or aroused his interest. If you want to access such data or refer to one of your other rights (such as the right to object to the processing of your data), please contact the provider of the relevant social platform. Some social media providers provide Sollers aggregate data about our pages, including information on the number of likes in response to our content or the number of entries, visitors to our pages, images downloaded by users or clicks on links posted.

Social media plug-ins (such as "like" and "share" buttons).

On our site we can use the so-called social media plugins. When a user enters a page with one or more of these buttons, his browser establishes a direct connection to the server of the social network and downloads the direct button from that server. At the same time, the social media provider will know that the user has visited the relevant page on our site. We have no influence on the data collected by social media providers using these buttons. To prevent the collection of such information, you must log out of your social media account before visiting our website. In addition, social media providers set cookies, unless the user blocks the acceptance and storage of cookies in their browser settings.

Contact Sollers via e-mail

Persons conducting e-mail correspondence with Sollers.

Sollers uses various tools to maintain the security of IT infrastructure, including email.

In the case of e-mail correspondence with Sollers, messages received from the user will be scanned using tools used by Sollers to secure their IT infrastructure, which may lead to situations in which the content of the message will be read by authorized persons from Sollers who are not its final recipient.

Legal grounds for processing personal data of persons conducting correspondence by e- mail with Sollers:

Realization of a legitimate interest in securing IT infrastructure against unauthorized access and data leakage.

Encryption method

Personal data . We also take technical and organisational precautions to protect your personal data which is managed by us from accidental or wilful manipulation, loss, destruction or from access by unauthorised individuals. We improve our data processing and security measures on an ongoing basis in line with technological advancements. Please note, however, that we cannot ensure full data security when you use e-mail as your communication medium.

Parental consent

If the user of Sollers website is under the age of 16 (or 15 if the user is French resident),, a visit is possible only after obtaining consent given by the holder of parental responsibility.

Security. Sharing Personal Data and processing locations

The Controller has a framework of procedures and trainings aimed at keeping your personal data safe and ensuring security and confidentiality. These are regularly reviewed to assess the appropriateness of the measures the Controller has in place to keep the data he holds secure.

The Controller only share personal data with others when he is legally permitted to do so, putting in place security mechanisms and contracts to comply with the Controller’s security, confidentiality and data protection standards and policies.

The personal data that we hold, may be transferred to:

Other Sollers Consulting Companies, the Controller will do this if this is necessary for administrative purposes and to provide professional services to the Controller’s clients. The Controller’s business contacts are visible to and used by the Controller’s employees to allow them to find out more about a specific contacts, leads, opportunities or projects they are interested in. In case you want to know more about processing this type of data, please see the Business Contacts section of the Privacy Policy.
the Controller’s sub-contractors that help to provide to the Controller’s Clients professional services.
Professional advisors and auditors, if needed.
Third party organizations that provide applications/functionality, data processing or IT services to the Controller. A part of the Controller’s IT systems are provided or ran by third parties, e.g. providers cloud-based software as a service, website hosting and management, data backup, security and storage services. The servers powering and facilitating that cloud infrastructure for the Controller are located in secure data centers in the EU.
Third party organizations that provide the Controller with goods, information or services.
Third parties as required by law. It may happen that the Controller will need to share personal information with e.g. law enforcement bodies or governmental agencies in order to be compliant with the applicable law. This is when the need to establish, exercise or defend legal rights or to investigate an alleged crime arises.

Exercising individual rights

When their data is processed, individuals have certain rights data controllers and processors are responsible for fulfilling these rights. Please find below a list of rights that you have and how to exercise them from us, the Data Controller:

Access to personal data

You have the right of access to your personal data held by the Controller as a data controller. If you want to exercise it and ask the Controller what personal data is he processing, send an e-mail at [email protected] The Controller will respond to your request as promptly as possible, within the legally required time limits.

Withdrawal of consent

In general, the Controller do not process data based on consent. This is because usually the Controller can rely on another legal basis. In cases where the Controller rely on consent, you have the right to withdraw it at any time. To withdraw consent to the Controller’s processing of your personal data, send an e-mail at [email protected] or, to stop receiving an email from the Controller’s marketing list, please click on the unsubscribe link in the received email.

Amendment of personal data

Whenever the Controller become aware that the personal data that he processes is no longer accurate, the Controller will make the appropriate amendments. In case you want to update the personal data that the Controller is processing, please send an e-mail to [email protected]

Other rights

Starting May 25th, 2018, you will have the right to demand erasure of your personal data, to demand restrictions in processing and the right to data portability. If you wish to exercise those rights, please send an e-mail to [email protected]

Complaints

If you want to complain about the Controller’s use of your personal data, please send an email with the details of your complaint to [email protected]. The Controller will investigate and reply to your complaint as soon as possible.

You also have the right to lodge a complaint with the Office for Personal Data Protection (UODO, Poland), Federal Commissioner for Data Protection and Freedom of Information (BfDI, Germany), National Commission on Informatics and Liberty (CNIL, France), Spanish Data Protection Agency (AEPD, Spain), the Personal Data Protection Commissioner (PDPC, Malaysia), Information Commissioner’s Office (ICO, UK). For further information on your rights and how to submit a complaint, please visit accordingly: the website of the UODO, the website of the BfDI, the website of the CNIL, the website of the AEPD, the website of the Personal Data Protection Commissioner, the website of ICO.

Data Controller: details and contact information

When processing personal data, the entity that decides why and how the data is processed is a Data Controller. The Data Controller in this case is Sollers Consulting Sp. z o.o. (registered in Poland under registry number 0000191247 and with registration address at 54 Koszykowa Street, 00-675 Warsaw, Poland) and other Sollers Consulting companies that are a contracting party for the purposes of providing or receiving services.

The Data Protection Officer was not appointed at the Controller in accordance with the applicable laws. In the structures of the Controller there is a special organizational unit dealing with processing and personal data protection issues. Contact with the abovementioned unit: [email protected].

If you have additional questions, please contact:

Sollers Consulting Sp. z o.o.

54 Koszykowa St.

00-675 Warsaw, Poland

e-mail: [email protected]

tel. no.: +48 (22) 272 92 22

The data controller of personal data collected and processed by Sollers Consulting Sp. z o.o. is Sollers Consulting (with its registered office in Warsaw, address: Warsaw (00-675), 54 Koszykowa St., entered into the register of entrepreneurs maintained by the National Court Register for the capital city of Warsaw, 12th Commercial Division of the National Court Register, under the number KRS 0000191247).

If you have additional questions, please contact:

Sollers Consulting Sp. z o.o.

54 Koszykowa St.

00-675 Warsaw, Poland

e-mail: [email protected]

tel. no.: +48 (22) 272 92 22

The data controller of the data processed by Sollers Consulting GmbH is Sollers Consultng GmbH (incorporated under German law), with its registered office in Cologne, Germany, Cäcilienstraße 30, 50667 Cologne, registered under the Handelsregister Amtsgericht Cologne under number HRB 83628. The Data Protection Officer was appointed at the Controller in accordance with the applicable laws. Contact with the abovementioned Data Protection Officer: [email protected].

If you have additional questions, please contact our Data Protection Officer:

Romina Moch

Sollers Consulting GmbH

Cäcilienstraße 30

50667 Köln

e-mail: [email protected].

tel. no.: +49 176 20337630

The data controller of the data processed by Sollers Consulting K.K. is Sollers Consulting K.K. based in TSR, Bldg. 3F 20-9 Nishishimbashi 1- chome Minato ku, Tokyo, Japan, number: 0100-01-192224, and other Sollers Consulting companies that are a contracting party for the purposes of providing or receiving services.

The Data Protection Officer was not appointed at the controller in accordance with the applicable laws. In the structures of the controller there is a special organizational unit dealing with processing and personal data protection issues. Contact with the abovementioned unit: [email protected].

If you have additional questions, please contact:

Sollers Consulting K.K.

TSR, Bldg. 3F

20-9 Nishishimbashi 1- chome

Minato ku (Minato City)

Tokyo 105-0003, Japan

e-mail: [email protected]

tel. no.: +81(0)3-6774-8743

The data controller of the data processed by Sollers Consulting SAS is Sollers Consulting SAS., based in Paris, 22 rue des Capucines, 75002 Paris, entered into the Registre du Commerce et des Societes, under RCS number: 888 208 097, number SIREN:888 208 097, number SIRET: 888 208 097 00020 and other Sollers Consulting companies that are a contracting party for the purposes of providing or receiving services.

If you have additional questions, please contact:

Sollers Consulting SAS

22 rue des Capucines

75002 Paris

e-mail: [email protected]

If you are a resident of United States of America, the data controller of your personal data is Sollers Consulting LLC (Limited liability company under the law of Delaware), based in Richmond, VA and address: 1806 Summit Ave, Suite 300 #1072, Richmond, VA 23230, registered by The Secretary of State of Delaware with Corporation Number – 6602341 and Authentication number – 202723053.

We process your data according to CCPA, DOPPA and other laws regarding data protection in the USA. You have right to know about the personal data a business collects about them and how it is used and shared, right to delete your personal data, the right to opt-out of the sale of their personal information, right to non-discrimination for exercising their CCPA rights, right to correct inaccurate personal data, right to request disclosure, right to access your personal data and other rights guaranteed by applicable law. If you are Californian resident please see our CALIFORNIA CONSUMER PRIVACY STATEMENT – SUPPLEMENT linked below.

We do not sell your personal data and we do not process your sensitive personal data.

In the structures of the controller there is a special organizational unit dealing with processing and personal data protection issues. Contact with the abovementioned unit: [email protected].

If you have additional questions, please contact:

Sollers Consulting LLC

1806 Summit Ave, Suite 300 #1072,

Richmond, VA 23230

e-mail: [email protected]

The data controller of the data processed by Sollers Consulting Information Technology SL is Sollers Consulting Information Technology SL, based in Valencia, Spain, 46021-Valencia, Avenida de Aragón, número 30, 8ª planta, oficina 846, entered into Registro Mercantil, under NIF number: B10970788 and other Sollers Consulting companies that are a contracting party for the purposes of providing or receiving services.

If you have additional questions, please contact:

Sollers Consulting Information Technology SL

Avenida de Aragón 30

46021-Valencia

e-mail: [email protected]

The data controller (data user) of the data processed by Sollers Consulting Sdn. Bhd. is Sollers Consulting Sdn. Bhd. based in Kuala Lumpur, Malaysia, Unit 37-2, Level 37, Q Sentral, No. 2A, Jalan Stesen Sentral 2, Kuala Lumpur Sentral 50470, Malaysia, entered into Registrar of Companies under Company registration number: 202301011497 (1505419-T) and other Sollers Consulting companies that are a contracting party for the purposes of providing or receiving services.

The Data Protection Officer was not appointed at the Data Controller (Data user) in accordance with the applicable laws. In the structures of the Data user there is a Contact person and special organizational unit dealing with processing and personal data protection issues.

If you want to contact us with any inquiries or complaints about our use of your personal data, please contact us via the method below:

Contact Person: Kamil Paziewski

Designation: Compliance Person, the Department of Personal Data Protection supporting companies belonging to Sollers Capital Group

Phone number: +60 11 1534 0399

Sollers Consulting Sdn. Bhd.

Unit 37-2, Level 37, Q Sentral, No. 2A, Jalan Stesen Sentral 2,

Kuala Lumpur Sentral 50470, Malaysia

e-mail: [email protected]

The data controller of the data processed by Sollers Consulting Information Technology Ltd. is Sollers Consulting Information Technology Ltd. registered in: 203 London Road Hadleigh Benfleet SS7 2RD, entered into Companies House under the Company number 14846071 having Tax Office number 623 and UTR number 45692 20510 and business address: 14 Cullum Street, London, United Kingdom, EC3M 7JJ, and other Sollers Consulting companies that are a contracting party for the purposes of providing or receiving services.

The Data Protection Officer was not appointed at the Data Controller in accordance with the applicable laws. In the structures of the Data user there is a special organizational unit dealing with processing and personal data protection issues. Contact with the abovementioned unit: [email protected].

If you have additional questions, please contact:

Sollers Consulting Information Technology Limited

14 Cullum Street, London,

United Kingdom, EC3M 7JJ

e-mail: [email protected]

If you become aware that the Controller’s employees or co-workers have violated the rules of personal data processing, please immediately send your information to the following address: [email protected].

Changes to this privacy statement

This privacy statement was last updated on 12th December 2023.

Once a year, the Controller conducts an audit of the correctness of personal data processing and its compliance with the applicable laws and the applicable instructions of the Office for Personal Data Protection.

Provided our commitment to processing data and informing you about your rights in a transparent way, the Controller will keep this privacy statement under regular review.

Detailed information about different types of personal data administered by Sollers Consulting

Business (sales-related) Contacts

Recruitment Privacy Policy

Other Contacts

California Consumer Privacy Statement - Supplement