Information on the Processing of Personal Data for entities purchasing USP Zdrowie products from USP Zdrowie’s business partners

In connection with the implementation of the requirements 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 (General Data Protection Regulation) (“GDPR”), we inform you about the rules for processing your personal data and your rights.

The following rules apply from 25 May 2018.

I. Indication of the Administrator

The administrator of personal data is USP Zdrowie sp. z o.o. with its registered office in Warsaw at ul. Poleczki 35, postal code 02-822, entered in the register of entrepreneurs maintained by the District Court for the capital city of Warsaw in Warsaw, the 13th Commercial Division of the National Court Register under KRS number 0000347815, NIP: 7010219241.

If you would like to contact us regarding matters related to the processing of personal data, please:

  1. sending an email to: [email protected],
  2. sending a letter to the address: USP Zdrowie sp. z o.o., ul. Poleczki 35, 02-822 Warszawa.

II. Purpose and legal basis for processing your personal data:

USP Zdrowie processes your personal data based on the premise of the legitimate interest of the administrator (Article 6(1)(f) of the GDPR), for the purpose of:

  1. ensuring optimal turnover of USP Zdrowie products within the serviced distribution network;
  2. enabling settlement with our partners (e.g., medical product wholesalers), who supply you with USP Zdrowie products;
  3. in order to monitor the sales performance of USP Zdrowie products;
  4. improving the quality of services provided and products offered; internal reporting of sales results within the USP Zdrowie framework or within the capital group to which USP Zdrowie belongs.

If you have given us consent for the processing of personal data, we will process your data within the scope and purpose specified in the content of the consent.

III. Categories of Processed Personal Data

In the event that USP Zdrowie did not obtain personal data directly from you, USP Zdrowie processes the following categories of data:

  1. identification data;
  2. address and contact details;
  3. transaction data regarding the turnover of USP Zdrowie products.

IV. Source of Acquisition of Personal Data

In the event that we have not obtained personal data directly from you, we inform you that personal data has been obtained from our business partner who supplies USP Zdrowie products to you.

V. Obligation to Provide Personal Data

The provision of your personal data is voluntary, however, it is necessary for business cooperation and settlement of trade conditions.

VI, Information about the recipients of your personal data

We transfer your personal data to:

  1. entities processing personal data on behalf of a company from the USP Zdrowie Group, including:
    1. external IT service providers who manage our IT systems and suppliers of goods or other service providers to companies within the USP Zdrowie Group (e.g., telephone service providers, postal and courier services);
    2. our partners responsible for providing physical security at our facilities and video monitoring;
  2. to entities affiliated within the USP Zdrowie Group for administrative and reporting purposes;
  3. state administration bodies within the limits arising from legal regulations.

VII. Periods of Personal Data Processing

Your personal data will be processed for the duration of your cooperation with our business partner, who provides you with USP Zdrowie products, and for the period of limitation of claims.

The above periods of personal data storage will apply most often. Due to the multitude of possible situations, your data may be stored for either longer or shorter periods than described above. Any questions regarding personal data storage periods should be directed to the address specified in point I of this Information.

VIII. Profiling and Automated Decision-Making

Your personal data will not be used for profiling, including automated decision-making.

IX. Rights of the data subject

You have a number of rights under the GDPR. You may submit a request to us for:

  1. access to personal data (in response, we will provide information on how we process your data and you will receive a copy of the data from us);
  2. rectification (i.e., correction) of personal data – in case the data is incorrect or incomplete;
  3. erasure of personal data (the so-called “right to be forgotten”). You can exercise this right, for example, when:
    1. we process personal data unlawfully,
    2. an objection was filed against the processing of data based on the legitimate interest of the company from USP Zdrowie and this objection will prove to be justified,
    3. data must be deleted in order for us to fulfill an obligation resulting from legal regulations;
  4. restriction of personal data processing (e.g., suspension of data operations or not deleting data due to certain circumstances);
  5. Transfer of personal data: to another controller, and when it is technically impossible, receive from us a copy of the data that has been provided to us.

From the right to data portability mentioned in point 5 above, you may only exercise this right when the processing is carried out by automated means, and additionally: (a) based on a contract that binds us, or (b) based on expressed consent.

To exercise the above rights, you can submit an application to the email address [email protected], or by sending a letter to our correspondence address: USP Zdrowie sp. z o.o., ul. Poleczki 35, 02-822 Warsaw.

X. Right to object

At any time, you may object to the processing of personal data if the basis for processing is our legitimate interest or when we act in the public interest. Upon receiving such a request, we will no longer be able to process the personal data covered by the request unless we demonstrate: a) the existence of valid legitimate grounds for processing that override your interests, rights, and freedoms, or b) grounds for establishing, pursuing, or defending claims.

XI. Right to withdraw consent for personal data processing

To the extent that you have given consent for the processing of personal data, you have the right to withdraw it. Withdrawal of consent does not affect the legality of processing carried out based on consent before its withdrawal.

XII. Right to lodge a complaint with a supervisory authority

In the event that the processing of personal data by USP Zdrowie violates the provisions of GDPR, you have the right to file a complaint with the supervisory authority.