Privacy Policy

Purpose of the Policy

The Policy applies to all websites within the domains www.asee.co and www.see.asseco.com, which are owned by ASEE, hereinafter referred to as the ASEE websites.

Asseco South Eastern Europe S.A. declares that ASEE websites are run with utmost care, in compliance with the rules of technical know-how and professionalism, as well as in accordance with the applicable legal regulations, in particular those that protect privacy of Internet website Users:

• Regulation No 2016/679 of the European Parliament and of the Council of the EU of April 27 2016 (GDPR);
• Act of July 18 2002 on the provision of services by electronic means;
• Act of July 16 2004 Telecommunication Law.

Revealing personal data

Please be informed that all companies belonging to ASEE Capital Group may have access to personal data and cookies files stored by ASEE websites. In such case transfer of such data fulfills all requirements arising from above mentioned legal regulations. The list of ASEE Capital Group companies is presented here: https://see.asseco.com/about/group-structure/.

In case when it is necessary for proper functioning of the ASEE websites or other purposes specified in this Privacy Policy where data processing of the users of websites is necessary, the processing of data can be entrusted to the entities not belonging to ASEE Capital Group. In such case the sub-processing of data is based on the data transfer agreements and fulfills all requirements arising from GDPR.

Data Collection

In accordance with the accepted practice of most of web services, we keep HTTP enquiries sent to our server. This means that we know the public IP addresses from which Users browse information content of our service. The browsed resources are identified by URL addresses. We also know the following:

• time the enquiry arrives; time taken to send the reply;
• name of client station – identification is executed by the HTTP protocol;
• information on errors that occurred while executing the HTTP transaction;
• URL address of the site previously visited by the User (referrer link) – if the transfer to the Office’s page was made through a link;
• information on User’s browser.

ASEE may collect information about you from the following sources:

• ASEE websites including temporary campaign landing pages
• Social media including but not limited to Linkedin, Twitter, Facebook, Instagram
• Events, sales activities, Customer files
• Contact persons from clients included in sales contracts

The information about you that ASEE may collect and process includes:

• name and address, e-mail address and telephone number;
• demographic data, when linked to personally identifiable information; photographs and opinions;
• work and educational history, achievements, test results and job qualifications transaction data, including products and services ordered, financial data and payment methods used;
• company data such as company name, size and location and your role in the company;
• survey data and publicly available information, such as posts from social networking sites;
• unique identifiers, such as mobile device identifiers or cookie identifiers in your browser;
• IP address and information that may be determined by the IP address, such as geographical location;
• information about the device you are using, such as your web browser, device type, operating system, presence or use of “applications”, screen resolution and preferred language;
• data about the behavior of a computer connected to the Internet or a device used to access websites, such as clicks on ads or their display, sites and their content, dates and times of activity or searches to locate and visit websites.

User Rights and Usage of Data

Regardless of the above, circumstances can be when information other than the above concerning the User, including personal data, will be indispensable to execute the requested service or process. Such is the case, the User will be informed of the necessity to make available of certain information, including personal data, and of the purpose of using such information.

The User is able to make a voluntary decision concerning making available or denial to make available of his/her personal data. Nevertheless, making available of personal data may be required in a situation when the User is interested in obtaining information concerning provision of a service, event specified as a part of ASEE websites. Thus, the User may be requested to fill in and send a form/questionnaire where it will be clearly indicated what kind of personal data and for what purpose will be gathered.

The personal data collected through ASEE websites may be used for the following purposes:

• marketing communication of own products or services,
• purposes of the recruitment process,
• using telecommunications end devices for the purpose of direct marketing, receiving commercial information by electronic means,
• providing information about the structure of ASEE Group
• for the purpose of satisfying legal requirements imposed on ASEE (Article 6 (1) (c) GDPR),
• in order to pursue our legally justified interest, including data archiving, protecting against claims and pursuing our own claims.

In a situation when the User reveals personal data of a third person in the form/questionnaire, it is assumed that the User has an appropriate consent of the person whose data he/she has revealed.

The User is entitled to view and the right to amend and complete any incorrect or incomplete personal data. Regardless of the above, the User is at any time entitled to demand that processing of his/her personal data is ceased – the data are deleted. The form of submitting such a request is specified while gathering such data.

We reserve that ASEE websites do not gather, monitor, or verify information on the age of Users visiting them or any other information gathering of which would enable ASEE to determine whether the User has a capacity to perform acts in law. Persons not having a full capacity to perform acts in law should not place orders or subscribe services provided by websites, unless their statutory representatives express their consent for this.

Cookie Files

ASEE websites use the so-called cookies or other technologies featuring functions similar or equivalent to cookies, i.e., information stored on the end device of Users visiting Websites. Cookies are automatically downloaded and used by Websites at each connection with the User’s end device. Saving data in cookie files and collecting data from the websites, requires your consent (Article 173 of Act of July 16 2004 Telecommunication Law).

ASEE websites use cookies in order to:

• adapt the contents of websites to the User’s end device, store individual settings of the User and to optimize the use of websites;
• improve safety by controlling violations in the process of using websites; obtain collective, anonymous statistics to improve functionality of websites;
• maintain User’s session (this refers to websites with user log on option) so the User does not have to re-log with his/her login and password on each website;
• enable the use of basic functionalities of websites (e.g., storing visited sites in order to reinstate them at User’s demand);
• for advertising and marketing purposes to adapt the advertising content displayed on ASEE websites and on other websites to User’s preferences.

Types of Cookies Used

• Session cookie files (temporary): stored on the User’s device only when websites are used, i.e. until logging off, closing a website or closing browser used by the User.
• Permanent cookie files: these remain at the User’s device until their life cycle ends (operating time parameterized for a cookie) or until removed by the User. Stored for 11 months.
• CSRF tokens: these are used to improve safety. Stored for 11 months.

Settings concerning the files are individual for each internet browser. Each User may choose to deny use of the cookies or limit cookie acceptance to a certain extent on his/her device. We inform that this can influence the comfort of using websites and result in a lack or improper display of a majority of websites.

If you accept cookies, it means that they will be placed in your end device and thus the ASEE Group will store information in your end device and access it.

Making Available of Websites

ASEE websites may include links to internet websites of other entities. Asseco South Eastern Europe S.A. has no influence on privacy policy of such entities and is not responsible for such a policy.

PR, Marketing and Recruitment

All information, including personal data, made available by the User as a part of ASEE websites and provided while the User participates in a range of various meetings organized by ASEE Group entities may be used for marketing and PR purposes as a part of various marketing campaigns conducted by ASEE Group entities if the User expresses his/her consent for that adequately based on GDPR or Act of July 16 2004 Telecommunication Law. User’s consent is equivalent to acceptance of receiving commercial information. Personal data will not be processed automatically (including profiling).

Asseco SEE websites may be involved in recruitment of new staff, interns, trainees, partners for Asseco South Eastern Europe S.A. or other ASEE Group entities. Personal data obtained in this manner are used for the needs of recruitment only as a part of current and future recruitment processes.

Personal data and information provided via ASEE websites may be used to develop and manage business relations by ASEE Group entities with a user representing a Partner or Client.

Data Transfer and Retention

The personal data provided to us may be transferred to, stored in, or accessed from a destination outside the European Economic Area (“EEA”), in particular the data may be transferred to the companies from ASEE Group seated outside EEA. It may also be processed by staff operating outside of the EEA who work for a ASEE Group.

The personal data are especially transferred within ASEE Group to the following countries outside the EEA, basing on standard contractual clauses: Republic of Serbia, territory of Kosovo, Bosnia and Herzegovina, Republic of North Macedonia, Republic of Moldova, Republic of Albania, Montenegro, Republic of Turkey, Andorra, Republic of Dominicana, Colombia, Peru, Egypt. The above list may be modified, the full current list of the countries can be found here: https://see.asseco.com/about/group-structure/.

Where ASEE transfers the personal data outside the EEA, it is ensured that it is protected in a manner that is consistent with how ASEE protects the data in the EEA.

How long the personal data is kept

As the general rule the data provided will be processed for the period necessary to achieve the purpose for which the data were provided, unless the law provides otherwise. The personal data will be processed for the following periods of time:

• for marketing purposes, the data is kept up to 5 years from the last contact
• for purposes of the recruitment process, the data is kept up to 2 years
• for purpose of receiving commercial information by electronic means, the data is kept up to 5 years from the last contact.

Contact Information (DPO)