[ SUCHENEK.LEGAL ]

§ PRIVACY POLICY. //

This Policy is for information purposes. It fulfils the Law Firm’s information obligations as data controller under Articles 13 and 14 of 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).

This Policy describes the rules for processing personal data on the suchenek.legal website (the Website) and outside it, in connection with the provision of legal services and other activities of the Law Firm indicated in section 1.1.

1. Data controller

1.1. The controller of the personal data of Website users, including recipients of alerts and the newsletter, persons visiting the Website, persons using legal services, business partners and persons contacting the Law Firm (Users), is Kancelaria Adwokacka Adwokat Karolina Suchenek, ul. Widok 8/5, 00-023 Warsaw, Poland, Tax ID (NIP) 1251758479 (the Law Firm).

1.2. Contact with the controller: kancelaria@suchenek.legal, tel. +48 515 139 065, or at the correspondence address given in section 1.1.

2. How data is processed

2.1. The scope, purposes, legal bases and periods of processing of personal data by the Law Firm:

2.2. Purpose: providing access to the Website

2.2.1. Scope of data: IP address.

2.2.2. Legal basis: Article 6(1)(f) GDPR, the Law Firm’s legitimate interest in making the Website available and ensuring its security.

2.2.3. Retention period: up to 6 months from collection. If the data is needed to defend against or pursue claims, until the limitation period for those claims expires.

2.3. Purpose: providing legal services under a concluded agreement

2.3.1. Scope of data: first name, surname, telephone number, email address, details of the business activity conducted, details of the employer, principal or client, position, and other data provided in connection with the matter.

2.3.2. Legal basis: Article 6(1)(b) GDPR, performance of a contract or steps taken before entering into it, where the client is the data subject; Article 6(1)(f) GDPR, the Law Firm’s legitimate interest in performing the contract with the client, where the data concerns the client’s employees, members of governing bodies, attorneys-in-fact or other persons connected with the matter; Article 6(1)(c) GDPR, obligations under the law; Article 9(2)(f) GDPR, where special categories of data (e.g. health data) are processed in the matter, to the extent necessary for the establishment, exercise or defence of legal claims.

2.3.3. Retention period: until the limitation period for claims connected with the legal assistance provided expires, and, for documents whose retention is required by law, for the period specified in the relevant provisions.

2.4. Purpose: organising meetings, including online and telephone meetings, and recording them

2.4.1. Scope of data: first name, surname, email address, telephone number, image and voice (in the case of a recording), and other data disclosed during the meeting.

2.4.2. Legal basis: Article 6(1)(f) GDPR, the Law Firm’s legitimate interest in organising meetings with clients, prospective clients and partners and in documenting arrangements made at the meeting. The Law Firm records a meeting only after informing participants at its start. A participant may object to the recording (Article 21 GDPR).

2.4.3. Retention period: organisational data until the matter to which the meeting related is concluded. Recordings until the commissioned services have been performed, and no later than 6 months after the matter is concluded, or until an effective objection. In the event of a dispute, until the limitation period for claims expires or the proceedings are concluded.

2.5. Purpose: partnership cooperation

2.5.1. Scope of data: first name, surname, email address, telephone number, details of the business activity conducted, details of the employer, principal or client, position.

2.5.2. Legal basis: Article 6(1)(b) GDPR, performance of a contract or steps taken before entering into it, where the partner is the data subject; Article 6(1)(f) GDPR, the Law Firm’s legitimate interest in performing the contract with the partner, where the data concerns the partner’s employees or representatives.

2.5.3. Retention period: until the limitation period for claims connected with the cooperation expires. Unless there is a justified suspicion that the data will be needed to defend against or pursue claims, the data is deleted no later than 6 months after the cooperation ends.

2.6. Purpose: sending legal alerts, the newsletter and other materials, e.g. e-books

2.6.1. Scope of data: email address and, if the User provides them, first name and company name.

2.6.2. Legal basis: Article 6(1)(a) GDPR, the User’s consent given when subscribing on the Website or in another way, e.g. when downloading an e-book; consent to receive commercial information by electronic means required by Article 398 of the Act of 12 July 2024 – Electronic Communications Law.

2.6.3. Retention period: until consent is withdrawn. After consent is withdrawn, the Law Firm may keep the email address and the record of consent until the limitation period for claims expires, in order to demonstrate that the mailing was lawful (Article 6(1)(f) GDPR).

2.7. Purpose: handling enquiries sent via the contact form, by email or by telephone

2.7.1. Scope of data: first name, surname, company name, email address, telephone number, the content of the message and data contained in attachments sent.

2.7.2. Legal basis: Article 6(1)(f) GDPR, the Law Firm’s legitimate interest in replying to the enquiry.

2.7.3. Retention period: up to 1 year from the end of the correspondence, or until a decision not to use the Law Firm’s services is taken, if that happens earlier.

2.8. Purpose: issuing invoices and keeping accounting records

2.8.1. Scope of data: first name, surname, company, NIP, REGON, business address, email address.

2.8.2. Legal basis: Article 6(1)(c) GDPR, a legal obligation incumbent on the Law Firm.

2.8.3. Retention period: for the period required by law, in particular Article 86 § 1 of the Tax Ordinance (5 years from the end of the calendar year in which the tax payment deadline expired) and Article 74 of the Accounting Act.

2.9. Purpose: traffic analysis and Website statistics

2.9.1. Scope of data: IP address, statistical cookies.

2.9.2. Legal basis: Article 6(1)(a) GDPR, the User’s consent given in the cookie banner.

2.9.3. Retention period: until consent is withdrawn or the data ceases to be useful.

2.10. Purpose: defending against and pursuing claims

2.10.1. Scope of data: first name, surname, email address and other data provided during cooperation.

2.10.2. Legal basis: Article 6(1)(f) GDPR, the Law Firm’s legitimate interest in defending against and pursuing claims, where there is a justified suspicion that the data will be needed for this purpose.

2.10.3. Retention period: until the limitation period for claims expires or the proceedings are finally concluded.

2.11. Providing the data needed to conclude and perform a legal services agreement or a cooperation agreement is a condition of concluding it. Providing invoice data results from tax regulations. In other cases, providing data is voluntary. Failure to provide data may make it impossible to reply to an enquiry, organise a meeting or send alerts and the newsletter.

2.12. The Website uses Google Analytics, provided by Google Ireland Limited. Statistical data may be transferred to Google LLC in the United States. The basis for the transfer is the European Commission implementing decision of 10 July 2023 finding an adequate level of protection under the EU-US Data Privacy Framework (Article 45 GDPR).

2.12a. Where another provider of IT, email or messaging services transfers data outside the European Economic Area, the transfer takes place on the basis of a European Commission decision finding an adequate level of protection (Article 45 GDPR) or standard contractual clauses (Article 46(2)(c) GDPR).

2.13. The Law Firm does not carry out profiling or automated decision-making on the basis of personal data.

2.14. The Law Firm may obtain personal data from sources other than the data subject: from a client or partner (the employer, principal or client of that person), from the opposing party, from courts and authorities, and from public registers, e.g. the National Court Register (KRS), CEIDG, land and mortgage registers. These are identification and contact data, data on the function or position held, and information relating to the matter. The Law Firm processes them for the purposes indicated in sections 2.3, 2.5 and 2.10.

2.15. The Law Firm does not provide the information referred to in Article 14 GDPR where the data is covered by attorney-client privilege (Article 14(5)(d) GDPR).

2.16. Information obtained in connection with the provision of legal services is covered by attorney-client privilege under Article 6 of the Act of 26 May 1982 – Law on the Bar.

3. Recipients of data

3.1. The following may process data on behalf of the Law Firm: the Website hosting provider, the email operator, the IT services provider, the provider of the alerts and newsletter service, the provider of Website traffic analysis tools (Google Ireland Limited, Google Analytics), the provider of online meeting tools and the accounting office. These entities act under a data processing agreement (Article 28 GDPR).

3.2. A processor may entrust data to a further processor only with the Law Firm’s prior consent (Article 28(2) GDPR).

3.3. Recipients of data may include cooperating attorneys, legal advisers, translators and partners of the Law Firm. They process data as separate controllers, within the part of the matter or joint project entrusted to them.

3.4. Personal data may be disclosed to courts and state authorities where this is necessary to conduct the matter or results from legal provisions. Courts and authorities are separate controllers.

4. Rights of data subjects

4.1. Every User has the right to: (a) access their data and have it rectified (Articles 15 and 16 GDPR), (b) erasure of data (Article 17 GDPR), (c) restriction of processing (Article 18 GDPR), (d) data portability, where processing is carried out on the basis of consent or a contract by automated means (Article 20 GDPR), (e) object to processing based on the Law Firm’s legitimate interest (Article 21 GDPR), including to the recording of meetings, (f) withdraw consent at any time, without affecting the lawfulness of processing carried out before its withdrawal, (g) lodge a complaint with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), ul. Stawki 2, 00-193 Warsaw.

4.2. These rights may be limited by the duty to maintain attorney-client privilege and by obligations arising from legal provisions.

4.3. To exercise these rights, contact the Law Firm in the manner indicated in section 1.2. Unsubscribing from alerts and the newsletter is also possible via the link in each message.

5. Server logs

5.1. The server records in log files information about requests: IP address, date and time of the request, number of bytes sent, the address of the previously visited page, and information about the browser and errors. The logs are used to administer the Website and are kept for up to 6 months (section 2.2).

5.2. Only persons authorised to administer the system have access to the logs. The logs may be used to compile aggregate traffic and error statistics that do not identify the User.

6. Security

6.1. The Law Firm applies technical and organisational measures appropriate to the risks and the categories of data protected (Article 32 GDPR). It protects data against disclosure to unauthorised persons, processing in breach of the law, and alteration, loss, damage or destruction. The connection to the Website is encrypted with an SSL certificate.

6.2. Using the Internet carries the risk of a device being infected with malware and of unauthorised third-party access to data. Users should use up-to-date antivirus software.

7. Cookies

7.1. The Website uses cookies, i.e. small text files saved by the browser on the User’s device. They usually contain the address of the website, the date saved, the period of validity and a unique number.

7.2. The Website uses session cookies, deleted when the browser is closed, and persistent cookies, which remain on the device until their validity period expires or they are deleted.

7.3. First-party cookies are saved by the Website and cannot be read by other websites. Third-party cookies are saved by the providers of tools used on the Website; they may be read by those providers’ servers.

7.4. Necessary cookies are used to maintain the session and to remember the selected language version and cookie settings. They do not require consent.

7.5. Statistical cookies are used to analyse the Website’s audience: the number of visits, navigation paths and time spent on the site. For this purpose the Website uses Google Analytics (cookies _ga and _ga_*, stored for up to 2 years).

7.6. Cookies other than necessary ones are saved only after consent is given in the cookie banner (Article 399 of the Act of 12 July 2024 – Electronic Communications Law). The scope of cookies saved depends on the consents given by the User.

7.7. A list of cookies, their providers and retention periods is available in the cookie banner.

7.8. The User may change cookie settings at any time in the banner or in the browser settings. Disabling necessary cookies may limit the functioning of the Website.

7.9. The User may delete saved cookies at any time following the browser manufacturer’s instructions.

8. Final provisions

8.1. This Privacy Policy is effective from 27.10.2026.

8.2. The Law Firm informs of changes by publishing a new version on the Website.