We attach great importance to protecting your privacy in our business. The personal data you entrust to us is necessary for us to conduct our business and offer you our products and provide our services. Without them, this would be impossible. Being aware of this, we take the utmost care to ensure that the data processed is completely confidential and secure, complying with the provisions of the applicable 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 (hereinafter referred to as “GDPR”).

Acting pursuant to our duty of information towards you under the GDPR, we advice as follows:

Who is the Controller of your personal data?

The Controller of your personal data is RESPECT ENERGY HOLDING spółka akcyjna with its registered office in Warsaw, ul. Ludwika Rydygiera 8, 01-793 Warsaw (hereinafter referred to as “RESPECT ENERGY” or “CONTROLLER”), entered in the Register of Businesses under KRS: 0000651850, NIP: 9522154698, REGON: 366078501. As the Controller, in accordance with the regulations, we are fully responsible for the protection and security of the processing of the data that you entrust to us or that we obtain from other sources, in accordance with the GDPR.

In the RESPECT ENERGY Group (RE Group), in which RESPECT ENERGY HOLDING S.A. is the parent company under the provisions of the Commercial Companies Code, the personal data security system is decentralised. This means that each company in the RE Group is a separate controller of the personal data it processes.

Who can you contact about data protection issues – the Data Protection Officer (DPO)?

The Controller has not appointed Data Protection Officer (DPO). The tasks of the DPO at RESPECT ENERGY are performed by the Management Board’s Security Officer. In matters related to data processing, you can contact the Security Officer via email address: pbi@respect.energy or by telephone: +48 512305151, as well as by letter writing to the RESPECT ENERGY’s address indicated above.

What is the legal basis for our processing of personal data?

RESPECT ENERGY processes your personal data pursuant to the GDPR, the national legislation applicable in this area, as well as its own Data Privacy policy.

The processing of personal data is carried out in compliance with the legal bases described in the GDPR, i.e.:

• with your consent to process your data for an explicit purpose,
• when necessary for the performance of an agreement or to take action on your behalf prior to the conclusion of the contract,
• when necessary in order to comply with a legal obligation incumbent on RESPECT ENERGY,
• when necessary to protect your vital interests (e.g. in connection with matters having impact on life or health),
• when there is a legitimate interest of RESPECT ENERGY (e.g. resulting from the need to secure rights from entrusted assets).

Why do we process your personal data?

RESPECT ENERGY processes your personal data in connection with its business activities, in order to:

• provide services and supply goods, in accordance with common law and the terms of the concluded agreements,
• enable you to benefit from the promotional campaigns, competitions and other activities in which participation would not be possible without the processing of your personal data,
• comply with RESPECT ENERGY’s obligations under common law, which the company is required to fulfil, inter alia, when processing personal data (e.g. those described in the Labour Code – in connection with employment, the Civil Code – in connection with terms of cooperation, the Accounting Act, tax legislation and others – in connection with the need to comply with requirements for business entities),
• take up employment or cooperate with RE Group companies,
• provide support in matters of health and life, in line with our Corporate Social Responsibility (CSR) policy,
• ensure that you and RESPECT ENERGY are able to assert claims arising from the contracts performed, in connection with civil law, as well as from other titles , including the rights arising from ownership and use of assets; and
• carry out any business or social activities that require the processing of personal data.

What is the scope of your personal data processing (categories of data and processing activities)?

RESPECT ENERGY primarily processes your data as the data of our customers and partners (including suppliers), as well as employees and associates, and as candidates for employment with RESPECT ENERGY Group companies, to the extent necessary for the establishment of cooperation and the performance of concluded agreements. In particular, we process the following categories of data:

Our Customers/ Prospective customers:

• identification data (first and last name(s), date of birth, address of residence/registered place of residence/point of collection, PESEL number / NIP number),
• contact details (mailing address(es), telephone number(s), e-mail address(es),
• data relating to our proposals/ performance of concluded agreements (agreement terms, volumes/quantities of energy/gas or other products and services sold, value of invoices/bills issued and the data contained therein, balance of payments for deliveries made, including commitments).

All information and offers of a commercial nature are made only with your consent and in compliance with the provisions of the law on the provision of services electronically.

Our Partners/Suppliers/Manufacturers:

• identification data (first and last name(s), date of birth, address of residence/registered place of residence/point of collection, PESEL number / NIP number),
• contact details (mailing address(es), telephone number(s), e-mail address(es),
• data related to the proposal/performance of concluded supply agreements (content of agreements, data on the subject of the supply, volume/quantity of purchased energy/gas or other products and services – including land for RES investments, values of received invoices/ bills and data contained therein, balance of settlements for completed supplies, including receivables from RESPECT ENERGY).

Our potential Employees and Associates (candidates for employment/co-operation):

• identification data (first and last name(s), date of birth, address of residence/registration),
• contact details (mailing address(es), telephone number(s), e-mail address(es),
• data on the applicants’ competences (education, work experience, skills and other information provided by the applicant in the curriculum vitae (CV) and in the motivation letter),
• other categories of personal data, if required by law (e.g. criminal records for members of company authorities/brokers/traders)

Our Employees and Associates (persons employed in RE Group companies:

• data required by common law, in particular the Labour Code and the Civil Code – to the extent covered by a separate information clause,
• data related to the participation of Employees and Associates in employment promotion campaigns and other projects and the performance of current job duties – to the extent covered by separate consents and clauses.

RESPECT ENERGY’s business activities require the conclusion of a number of agreements with a variety of subjects and conditions relating to the processing of personal data. In such cases, separate information clauses are used, corresponding to the specific nature of the subject of the agreements and the processing conditions applicable to them. In such cases, the most frequently processed data are those of persons representing the parties to the agreements and persons responsible for their execution. 

It is then necessary to process the following categories of data: 

• identification data (first and last name(s), role(s) and/or official position(s) held, name of contracting party),
• contact details (mailing address(es), telephone number(s), e-mail address(es),
• criminal record (occasionally when required by applicable law).

The scope of data processing activities includes in most cases:

• ata entry,
• data display/viewing,
• data storage,
• updating of data (adapting or modifying),
• data sharing,
• data restriction/deletion or destruction,
• other processing activities (collection, recording, organisation, structuring, use, matching or linking).

Processing activities are carried out by trained and authorised employees, associates and entities processing personal data pursuant to an authorisations and processing entrustment agreements/clauses. 

How long will we process your personal data?

Personal data in connection with agreements concluded with Customers, Partners and Associates), is processed throughout the period of service provision. We also process the data after the expiry or termination of the agreement for a period of 5 years, as of the date of approval of the financial statements for the year and thus from the beginning of the year following the financial year, in connection with the obligations under the tax regulations and the Accounting Act.

In order to ensure that claims related to the services provided can be asserted, we process personal data for the period of limitation of claims for RESPECT ENERGY’s business activities specified by law, in particular the Civil Code. This is primarily related to the timelines of proceedings before common courts.

In the case of RESPECT ENERGY employees, the data collected in personnel files are retained in the company archives for a period of 50 or 10 years, starting from the year of termination of employment, and then in the national archives under separate regulations on the retention period of employee records.

We retain social security data for 10 full years from the year of termination of employment.  

Records of employment-related financial settlements are retained for 5 full years from the year in which the financial statements are approved.

We process the data of job applicants for the duration of the recruitment procedure for which the data is processed, but no longer than 12 months from the date of the procedure.

For Employees, Associates and Job Candidates of RE Group companies, the information about personal data processing timelines is provided in separate clauses.

What rights do you have in relation to the processing of your personal data?

In connection with RESPECT ENERGY’s processing of your personal data, you have the right to:

• access your personal data and request a copy of it,
• rectify your personal data,
• request the restriction of the processing of your data,
• object to the processing if the processing goes beyond the scope of the stated purpose,
• delete the data when it is processed for purpose other than stated or when the purpose of the data processing has ceased to exist.

The request for data erasure or restriction of processing applies only to the categories of data processed with your consent. However, complying with this request may deprive you of the benefit of discount policies or participation in marketing and promotional activities, so please consider your decision carefully.

Right to lodge a complaint with a supervisory authority

Please be informed that if, for legitimate reasons, you consider that RESPECT ENERGY’s processing of the entrusted personal data violates the provisions of the GDPR, you have the right to lodge a complaint against our actions with a competent supervisory authority which is the President of the Office for the Protection of Personal Data, 2 Stawki Street, 00-913 Warsaw.

As Data Controller, we have implemented GDPR provisions into our management system, which we keep improving based on new experiences in our relationship with you. Therefore, we will appreciate if you can point out to us any potential irregularities or objections concerning our processing of your data. We will treat any such reports as our priority areas for improvement.

What are the consequences of not providing personal data?

The obligation to provide personal data is related to the conclusion of an agreement and its performance. It derives from the law, for the purposes and to the extent described in Section 3 above.

You have the right to refuse to provide your personal data, but please bear in mind that you will then be unable to enter into and agreement with us and take advantage of our range of products and services offered or take up employment with us.

Czy dane osobowe będą przekazywane innym podmiotom (odbiorcom, podmiotom przetwarzającym)?

RESPECT ENERGY may disclose the personal data processed to state institutions and authorities which are authorised to have access to such data under special laws during the processing period (i.e. tax offices, tax inspection authorities, the Social Insurance Institution, the National Labour Inspectorate, courts and the Police and other authorities responsible for public security).

The processors of personal data contained in agreements or provided by Customers, Partners, Employees and Associates are other RE Group companies, including:

• RESPECT ENERGY HOLDING S.A., with its registered office at 8 L. Rydygiera St., Warsaw, is the entity that processes personal data on behalf of and for the benefit of all RE Group companies to the extent primarily related to HR and payroll services and the maintenance of business records,
• RESPECT ENERGY S.A., with its registered office in Warsaw at ul. L. Rydygiera 8, processes personal data in connection with the provision of services related to its energy and gas trading activities on the exchange and institutional markets,
• RESPECT ENERGY IT Solution Sp. z o.o., with its registered office in Warsaw at ul. L. Rydygiera 8, provides comprehensive ICT services to RE Group companies,
• RESPECT ENERGY Towarowy Dom Maklerski Sp. z o.o., with its registered office in Warsaw at ul. L. Rydygiera 8, which conducts brokerage activities,
• RESPECT ENERGY Solar Wind Sp. z o.o., with its registered office in Poznań at ul. Naramowicka 76, to the extent related to RES infrastructure development projects,
• Other RE Group entities, in connection with intra-group cooperation.

Processing is carried out under processing outsourcing agreements drawn up in accordance with the provisions of the GDPR, taking into account the rights of data subjects and ensuring the security of the data processed.

RESPECT ENERGY will not transfer your personal data to other entities. Data subjects will be informed of such disclosure should the need arise.

RESPECT ENERGY may only transfer personal data to others at your request and with your consent.

RESPECT ENERGY will generally not transfer personal data outside the European Union or to persons outside the European Union. Currently, personal data is not transferred to recipients outside the European Economic Area (EEA). The exception is the data of Employees and Associates directly involved in the performance of ESG (Environmental-Social-Governance) obligations and the internationalisation of the RE Group’s activities.

Do we use cookies and how??

RESPECT ENERGY uses cookies. The Company’s Board of Directors considered this decision at length, analysing the marketing benefits of meeting your needs and expectations, as well as the potential risks to the security of the data processed. Given the minimal level of negative factors with obvious benefits in communicating with you, the decision was taken to use cookies, especially as the final decision to disable them always remains in your hands.

a. Co to są i czemu służą pliki cookie („ciasteczka”)

Cookies (cookie files) are IT data, in particular including text files. They usually contain the name of the website from which they originate, the time they are stored on your terminal device and a unique number. These data are stored on your terminal device during the time you use the website. They are used to personalise the pages displayed, to facilitate logins and other operations on the website, to support advertisements and the monitoring of user activity on the website. As a result, institutions and companies can work continuously to improve the quality of the information provided.

The web browser usually allows the storage of cookies on the terminal device by default. Cookies are commonly used by entities communicating through websites.

b. Why do we use “cookies”?

Cookies allow us to:

• analyse how you use our website,
• track the traffic on our website which shows your interest in the presented content,
• manage more effectively the structure and content of the information presented,
• ensuring the proper functioning of the RESPECT ENERGY website at all times.

The cookies used by our website do not save or collect any of your personal data and cannot be used to identify you as a user of the website. 

c. How long do cookies remain on your device?

The type of file determines how long cookies remain on your terminal device. The files used in daily practice most often include: 

• session cookies – temporary file which are only active while you are using our website and disappear when you leave it,
• persistent cookies – permanent files which will appear if you frequently visit the RESPECT ENERGY website and remain on your device for some time.

The following types of cookies are used:

• cookies enabling the use of services available on the website, e.g. authentication cookies used for services that require authentication,
• cookies ensuring security e.g. used to detect misuse of the site’s authentication,
• cookies collecting information about the use of the websites,
• cookies which remember the User’s selected settings and help to personalise the interface, e.g. with respect to the language or region chosen, the design of the website, etc,
• cookies helping us to analyse how you use our website.

e. Can you control cookies and how do you decide on their use?

The decision to use cookies is ultimately always yours.
When browsing the RESPECT ENERGY websites, you can change your cookie settings at any time, specifying the conditions for storing and accessing cookies on your device. You can change your settings via your browser configuration. In particular, you can change your settings in such a way as to disable the automatic handling of cookies in your web browser configuration or to demand information whenever cookies are placed on your device.
If you wish to restrict or disable cookies, you can do so via the browser settings on the terminal device you are using. Each browser has a “HELP” section where you will find information on how to disable and delete cookies. Below are links to cookie management instructions for selected web browsers:

Chrome http://support.google.com/chrome/bin/answer.py?hl=pl&answer=95647
Internet Explorer http://support.microsoft.com/kb/196955/pl
Firefox http://support.mozilla.org/pl/kb/ciasteczka
Opera http://help.opera.com/Windows/8.0/pl/cookies.html

When deciding on the use of cookies, it is important to bear in mind that disabling the storage of cookies may result in restriction of the website functionality or inability to use certain features of the website.