Privacy policy

GENERAL INFORMATION

The GTV Group (also referred to hereinafter as: “GTV” or “we/us”) provides its services in many countries through entities that, in connection with their operations, may process your personal data. In this Privacy Policy of GTV (hereinafter: the “Policy”) we provide you with general information regarding the principles by which we process your personal data and the rights you have in connection with that processing.

We emphasize that we take the protection of your personal data very seriously and exercise due diligence to process such data securely. To protect your personal data while increasing the value of the services we provide and offering greater capabilities, we comply with legal provisions, in particular 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) (Official Journal of the EU L 119, p. 1) (hereinafter: “GDPR”).

Wherever in this document we use the term GTV Group (also in the versions of the terms defined above), it means that a given piece of information may be applicable to any entity belonging to the GTV Group mentioned in this document and therefore that entity may process your personal data as a controller, for the purposes and in the manner described in this Policy. The entities referred to in the preceding sentence are listed in the section Entities responsible for applying the Policy. If a specific matter indicated in the Policy concerns only a particular entity, you will be informed accordingly.

At the same time, we point out that the manner of processing your personal data may differ depending on the relationship you have with a given entity, the country in which that entity operates, and the specifics of the industry in which that entity operates, which may be the owner of various brands with their own websites. In cases where a website owned by a company from the GTV Group has its own dedicated privacy policy, this document does not apply.

In situations where your personal data are processed for purposes other than those indicated in this document, you will be informed accordingly by the entity that processes your personal data as a controller, via appropriate supplementary documentation.

ENTITIES RESPONSIBLE FOR APPLYING THE POLICY

This Policy generally applies to data processing by the following entities:

GTV Poland S.A. with registered office in Poland,

GTV Asset Management sp. z o.o. with registered office in Poland,

GTV Croatia d o.o. with registered office in Croatia,

GTV España Herrajes e Iluminación S.L. with registered office in Spain,

GTV Czech Distribution s.r.o. with registered office in the Czech Republic,

GTV Stolmet sp. z o.o. with registered office in Poland.

INFORMATION ABOUT DATA CONTROLLERS AND THEIR CONTACT DETAILS

As indicated above, different data controllers may be responsible for processing your personal data, depending on which controller you have a relationship with or which operates in the country where your personal data are collected.

The controller of your personal data may be:

GTV Poland S.A. with registered office in Poland, Pruszków (05-800), Przejazdowa Street 21 (hereinafter: “GTV Poland”)
Email address	info@gtv.com.pl

 

As a rule, GTV Poland will be the leading company with respect to the processing of your personal data, and therefore most of the information concerning the processing of personal data indicated in the Policy may relate to GTV Poland, about which we will inform accordingly.

At the same time, we indicate that GTV Poland is responsible for running and servicing the websites: www.gtv.com.pl, www.hoegert.com, www.hoegertworkwear.com, www.gtvdecor.com and www.enzeit.com

The controller of your personal data may also be:

GTV Asset Management sp. z o.o. with registered office in Poland, Pruszków (05-800), Przejazdowa Street 21,
Email address	info@gtv.com.pl

or

GTV Croatia d o.o. with registered office in Croatia, Zagreb (10110), Roberta Frangeša Mihanovica 9 (hereinafter: “GTV Croatia”)
Email address	croatia@gtv.com.pl

or

GTV España Herrajes e Iluminación S.L. with registered office in Spain, Valencia (46021), Avenida Aragón 30, 8th Floor (hereinafter: “GTV España”)
Email address	gtv@gtv.es

or

GTV Czech Distribution s.r.o. with registered office in the Czech Republic, Ostrava (720 00), Na Rovince 879
Email address	info.ostrava@gtv.com.pl

or

GTV Stolmet sp. z o.o. with registered office in Poland, Szczytno (12-100), Wincentego Pola Street 6
Email address	stolmet@gtv.com.pl

 

You can contact the selected controller in the following ways:

• by sending a message to the appropriate email address indicated above;
• by submitting a message via our contact form;
• by post, to the address of the relevant company headquarters indicated above.

CONTACT WITH DATA PROTECTION OFFICERS

Please note that some of the above-mentioned controllers have appointed Data Protection Officers, with whom you can contact via:

GTV Poland – you can contact the Data Protection Officer by sending an email to: dpo@gtv.com.pl or by post to the registered office of GTV Poland;

GTV Croatia – you can contact the Data Protection Officer by sending an email to: dpo.croatia@gtv.com.pl or by post to the registered office of GTV Croatia;

GTV España – you can contact the Data Protection Officer by sending an email to: lopd@gtv.es or by post to the registered office of GTV España.

WHAT DATA WE COLLECT

We usually receive your personal data directly from you. It may also happen that we receive your personal data from your employer or the entity you represent, e.g., when you sign a contract with us on behalf of your employer or contact us as the contact person for your employer. In such a case, we may obtain your identification and contact details such as your name and email address.

The manner in which we collect your personal data also depends on the circumstances in which we obtained your personal data. If you visit our websites, GTV Poland may collect certain personal data about you via cookies or other similar technologies (e.g., IP address). You can find more information about cookies in our Cookie Policy .

Your personal data may also be collected via forms available on GTV websites, e.g., when subscribing to a newsletter, where you may provide your contact details (email address), when filling in registration forms, accessing catalogs or the contact form, where you indicate your name and contact details (e.g., email address).

In addition to the examples above, we point out that your personal data may also be collected when you use our services or conclude a contract with us, e.g., a sales contract through our online stores.

PURPOSES AND LEGAL BASES FOR DATA PROCESSING

Below we set out the purposes and legal bases on which your personal data are most frequently processed. It may happen that your personal data will also be processed for purposes other than those described below. In such a case you will be informed separately, e.g., if you wish to participate in recruitment conducted by one of the companies from the GTV Group, we will provide you with information on the processing of your personal data for recruitment purposes.

Please contact us via the contact channels indicated above if you do not see a processing purpose that fits the relationship between you and us.

Purpose of data processing:	Legal basis for data processing:
Operating our websites (e.g., www.hoegert.com), including enabling user registration and providing services through these websites by GTV Poland	Performance of a contract for the provision of electronic services in accordance with the terms and conditions indicated on the site (Art. 6(1)(b) GDPR)
Obtaining access to the B2B platform (account creation)	Performance of a contract for the provision of electronic services in accordance with the terms and conditions indicated on the site (Art. 6(1)(b) GDPR)
Handling the matter you reported (e.g., via the contact form or email)	Handling and responding to questions submitted to us, which constitutes our legitimate interest (Art. 6(1)(f) GDPR) or performance of a legal obligation (Art. 6(1)(c) GDPR) where your message triggers the performance of such an obligation by us, e.g., where you submit a request to exercise rights under the GDPR
Concluding or negotiating the conclusion of a contract at your request. Performance of a contract with a party (contractor, partner or client)	Negotiating or entering into and performing a contract at your request (Art. 6(1)(b) GDPR)
Concluding or negotiating the conclusion of a contract at your request on behalf of our client, partner or contractor. Performance of a contract with a contact person	Negotiating or properly concluding and performing a contract with our client, partner or contractor, which constitutes our legitimate interest (Art. 6(1)(f) GDPR)
Providing services or selling products, including order fulfillment through the online store owned by GTV Poland (e.g., purchasing products via the www.hoegert.com store)	Performance of a contract (Art. 6(1)(b) GDPR)
Handling complaints (e.g., for products purchased in our online store)	Performance of a legal obligation (Art. 6(1)(c) GDPR), if the complaint results in the performance of such an obligation Performance of a contract (Art. 6(1)(b) GDPR), if the complaint results in the performance of such an obligation, e.g., in connection with a warranty agreement
Compliance with legal obligations	Legal provisions, in particular tax and accounting regulations (Art. 6(1)(c) GDPR)
Managing correspondence	Ability to manage correspondence and ensure circulation and archiving of documents (Art. 6(1)(f) GDPR)
Marketing by GTV Poland	Ability to promote our products and services, which constitutes our legitimate interest (Art. 6(1)(f) GDPR)
Sending marketing content by GTV Poland (newsletter, satisfaction surveys) regarding our products and services via the communication channel you selected (e.g., email)	The possibility to use the right to send marketing content based on the consent you have given to receive such content through the chosen communication channel (e.g., GTV newsletter), which constitutes our legitimate interest (Art. 6(1)(f) GDPR) or your consent to the processing of personal data for direct marketing purposes (Art. 6(1)(a) GDPR) in connection with the consent you have given to receive marketing content via the chosen communication channel
Displaying advertisements on websites tailored to your interests on behalf of GTV Poland (e.g., in cooperation with Google)	Ability to present offers and advertisements on websites, which constitutes our legitimate interest (Art. 6(1)(f) GDPR)
Analysis and statistics of sites managed by GTV Poland	Improving quality and verifying the effectiveness of the marketing content we present, which constitutes our legitimate interest (Art. 6(1)(f) GDPR)
Managing social media	Promotion of GTV products and services, which constitutes our legitimate interest (Art. 6(1)(f) GDPR)
Running contests	Execution of the contest according to its terms and conditions (Art. 6(1)(b) GDPR) or organization of the contest, including selection of winners, notifying winners, awarding prizes and handling possible complaints. Our legitimate interest is the proper organization of the contest as part of GTV promotion (Art. 6(1)(f) GDPR)
Establishing, pursuing and defending claims	Establishing, pursuing and defending claims, which constitutes our legitimate interest (Art. 6(1)(f) GDPR)

RECRUITMENT

Each controller has separately regulated matters related to recruitment (e.g., due to internal regulations applicable in the given country). Information on the processing of candidates’ personal data is provided in the relevant places when applying for a specific position.

SOCIAL MEDIA

We maintain profiles on social media where we may process your personal data. In some activities, for example for statistical purposes together with the social network operator, we may act as joint controllers. Information on how your personal data are processed on a given platform can be found below:

• Facebook and Instagram:

https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0

• LinkedIn:

https://pl.linkedin.com/legal/privacy-policy

• TikTok:

https://www.tiktok.com/legal/page/eea/privacy-policy/pl

• YouTube:

https://policies.google.com/privacy?hl=pl

DATA RETENTION PERIOD

The retention period for your personal data depends on the legal basis for processing. As a rule, we will process your personal data as follows:

• where the legal basis for processing your personal data is consent, we will process your personal data until you withdraw your consent;
• where we have a contract with you, we will process your personal data for the duration of the contract and then for the period required by statutes of limitations;
• where the legal basis for processing your personal data is a legal obligation incumbent on us, we will process your personal data for the period required by law;
• where the legal basis for processing your personal data is our legitimate interest, we will process your personal data for the time necessary to achieve our legitimate interest, and until you object to the processing of your personal data.

RECIPIENTS OF PERSONAL DATA

Recipients of your personal data may include:

• suppliers providing services to GTV, such as IT, hosting, marketing, transport and courier service providers, companies providing document destruction services, as well as social media operators and debt collection service providers;
• professional advisors, such as legal and tax advisors, audit firms, accounting service providers;
• entities within the GTV Group;
• state authorities, in cases provided for by law.

MANDATORY OR OPTIONAL PROVISION OF PERSONAL DATA

Providing your personal data is voluntary but may be necessary to conclude a contract with us, provide you with a service, handle your matter, participate in a contest, or may result in the inability to make a purchase in our stores. Where provision of data in a form is mandatory, we indicate this accordingly.

TRANSFER OF DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)

Considering the nature and scope of services offered by entities in the GTV Group, your personal data may, in justified cases, be transferred to entities located outside the European Economic Area (EEA). Where such countries have not been recognized by the European Commission as ensuring an adequate level of data protection, the entity responsible for transferring data to a country outside the EEA implements appropriate safeguards to ensure an adequate level of protection of your personal data, in particular through the use of standard contractual clauses approved by the European Commission. These measures serve to implement your data protection rights and ensure effective legal protection. The controller responsible for processing your personal data will provide you, upon request, with a copy of those safeguards.

WHAT RIGHTS DO YOU HAVE?

We are committed to respecting the confidentiality of your personal data and to ensuring you can exercise your rights. Regardless of the purpose or legal basis for which we process your personal data, you have the following rights:

• access to the content of the data we hold about you, including obtaining a copy;
• rectification or completion of the data, including correction and updating;
• erasure of personal data (the “right to be forgotten”), taking into account the circumstances that permit or exclude the erasure of your personal data;
• restriction of processing of your data, taking into account the circumstances that allow such restriction;
• objection to the processing of personal data where we process your personal data on the basis of our legitimate interest and the objection is justified by your particular situation. In addition, you have the right to object to the processing of personal data for the purposes of direct marketing;
• data portability where we process your personal data based on your consent or on a contract. This means you have the right to receive the personal data you provided to us in a structured, commonly used, machine-readable format, to allow it to be transmitted directly to another controller where technically feasible;
• withdrawal of consent to the processing of personal data at any time, which does not affect the lawfulness of processing based on consent before its withdrawal.

You may exercise the above rights via the appropriate contact details provided in the information about data controllers and their contact details, referred to above in the section information about data controllers and their contact details.

You also have the right to lodge a complaint with the data protection supervisory authority in your country of residence that is a member state of the European Union where we have an establishment.

CHANGES

We reserve the right to periodically review and modify this Policy in connection with any changes in the processing of your personal data or legal regulations. The date of the last modification is stated at the end of this document. In case of changes to this Policy and the way your personal data are used, we will make an updated version of this document available.

Last update of the Privacy Policy: 19 July 2024.