Privacy Policy

This Privacy Policy was last modified and is effective as of 1st of January, 2025.

This Policy applies to the processing of your personal data, as well as the use of "cookie" files and similar technologies by EL Passion Next sp. z o.o., with its registered seat at: Krakowskie Przedmieście 13, 00-071 Warszawa, Warsaw, Poland (“EL Passion”) as the controller of your personal data. This Privacy Policy applies to collection of your personal data in connection with provision of EL Passion’s services, collection through the EL Passion website: https://www.elpassion.com/ and through its mobile version (the “Website”), as well as through other channels as may be applicable (direct meetings, conferences etc.)

Your Privacy is important to us!

We recognize that your privacy is very important to you and that it is your right to control and be informed about the information we process about you and how we process it. We know that providing personal data is an act of trust and we take that trust seriously. We will not disclose your personal data to third parties, except as outlined in the Privacy and Cookie Policy and provided that we have an appropriate legal basis for such disclosure. 

By using our Services, contacting us through the Website, applying for a job with us or otherwise sharing your personal data with us, you agree to be bound by this Privacy Policy. 

1. Categories of personal data

a. Provision of Services: Conclusion and performance of any agreement for provision of Services involves personal data processing (name, surname, job title, corporate e-mail address) of natural persons (proxies, representatives, employees, contractors, etc.) transferred by the Client to EL Passion. This can include personal data of the Client himself/herself when a Client is a natural person. We process your personal data provided at the point of concluding a contract with you (name, surname, e-mail address, other relevant identification data) for the purpose of enabling your user access to our services. 

Insofar as the performance Services involves the processing of personal data of Client’s representatives, employees, contractors, etc., the Client acknowledges that this Privacy Policy is applicable to such processing and undertakes to provide such representatives, employees, contractors, etc. with its content.

b. Collection through the Website: In order to make contacting you possible, the Website may enable collection of certain personal data: name and surname, the company you work for, your e-mail address and/or phone number. Aside from your personal data, you may also be invited to provide additional data about your project etc. in order to receive an estimate from us. 

c. Applying for a job: If you are a job applicant, the data we process about you are your contact details, employment history related data, information about your education and professional qualifications. We may also process your data contained in the curriculum vitae (CV). We obtain data directly from you. 

2. Purposes and legal basis

The processing of your personal data by EL Passion is necessary for the purpose of managing client relationship, concluding and performing the Agreement with you or your company (including contacting for marketing purposes, unless EL Passion receives an objection to such processing), contacting you in response to your query, as well as exercising all the rights and obligations relating to the performance of the agreement.

In processing your data, we pursue our legitimate interest in (i) direct marketing of our services, (ii) enabling the provision of our services based on the agreement, (iii) exercising our contractual and legal rights and obligations, (iv) contacting you if you requested so through our Website or provided us with your data through other channels; (v) defense against potential legal claims. 

If the Client is a natural person, we process the personal data based on the contract, i.e. the processing is necessary for the conclusion and performance of the contract, to which the data subject is a party.

For job applicants: If you are applying for a job with us, your personal data is processed for the purpose of recruitment and conclusion of an employment/civil law contract for provision of services. 

The following legal bases apply:

a. the necessity to process your personal data in order to conclude and perform the contract with you and to take steps prior to conclusion of the contract;

b. legal obligation to collect certain personal data for recruitment and employment purposes;

c. explicit consent if you would like us to keep your application on file for future consideration (your consent can be withdrawn at any time, which will not affect legality of processing conducted prior to such withdrawal).

Provision of personal data is voluntary, but if you don’t provide us with the basic personal data, we will not be able to conclude and agreement with you, respond to your query or process your job application. 

3. Your rights

You have the right to object to the processing of your data by us (if we process it based on legitimate interest) and to request that we correct or delete your data. If you file such a request we will stop processing your data and we will delete it, unless there exists an important overriding legal interest (e.g. defense of claims or existence of a legal obligation to retain the data) that will entitle us to keep your data for a longer period. You also have the right of access to your data, as well as the right to data portability and to restriction of the processing. You also have the right to file a complaint to the Polish supervisory authority (Prezes Urzędu Ochrony Danych Osobowych).

4. Retention periods 

We process your personal data only for as long as necessary for the purposes, for which it was collected. As a general rule, we will process personal data for as long as we have a contractual relationship with the Client and/or for as long as you remain the contact person or employee/contractor of the Client, whichever is the earliest. We will also process the data after the termination of the contractual relationship, for the duration of the statutory period of 3 years. We may have to process personal data for a longer period of time in limited circumstances, i.e. in case we need to defend against legal claims.

If you are a job applicant who did not agree to the processing of your personal data for future recruitment purposes, we delete your data within 30 days as of the end of the recruitment process. If you agree to future processing, we keep your data on record for the period of 2 years, after which we may reach out to you and ask whether you still consent to the processing.

As regards personal data processed for marketing purposes, we keep your personal data for the duration of contractual relationship with the Client and for 2 years after its termination. For leads whit whom we do not have a contractual relationship, the applicable retention period is 2 years from the date of collection of personal data. 

5. Sharing your personal data with third parties

We entrust the processing of your personal data to entities, which act on our behalf and solely based on our instructions (data processors). In particular, we use data processors, whom we select carefully, to store your data on secure servers located within the territory of the EU. In the event that personal data is entrusted for further processing to subprocessors outside the EEA, we ensure that appropriate safeguards (in particular Standard Contractual Clauses) are in place to ensure the legality of such transfer and the security of your data.

We may have to share your personal data with competent authorities (in particular the police or prosecution service), if they approach us with such a request, provided that there exists an appropriate legal basis for making your personal data available to them (e.g. a court order).

6. Contact

If you have any questions with regard to the processing of your data by us or if you wish to exercise your rights, you can contact us by email. 

7. Modification of the Policy

We may periodically be required to make changes to our Privacy Policy (for example if we substantially change the way our Services or the Website functions or in response to legislative changes). We will notify you of these changes by posting the modified Privacy Policy on the Website. If the changes are substantial, we will also notify you by e-mail. We recommend that you revisit this Privacy Policy regularly. You may determine when this Privacy Policy was last updated by referring to the date found at the top of the first page of this Privacy Policy.

8. Our use of cookies and similar technologies

a. The Website does not use analytics, advertising or tracking cookies, web beacons or device fingerprinting, and does not set any cookies of its own.

b. Cookies are small text files that a website stores on your computer, phone or other device. Similar technologies, such as your browser’s local storage, work in the same way.

c. When you close the cookie information notice by clicking “OK”, your browser stores a single entry (elp-cookie-notice) in its local storage so that the notice is not shown again. This entry contains no personal data and is never sent to us. You can remove it at any time by clearing the site data in your browser.

d. Some pages contain embedded videos hosted by YouTube (Google Ireland Limited) or Vimeo (Vimeo.com, Inc.). YouTube videos are embedded in privacy-enhanced mode (youtube-nocookie.com) and Vimeo videos with the “do not track” setting. When you play a video, the provider receives your IP address and technical information about your device and may store information on your device under its own privacy policy: policies.google.com/privacy and vimeo.com/privacy.

e. The Website is hosted by Cloudflare, Inc., which processes technical connection data, such as your IP address, to deliver the Website and protect it against abuse. When you send the contact form, your IP address is also used to limit the number of submissions.

f. Because the Website only uses technologies that are necessary for it to work, we do not ask for consent to cookies; we inform you about them with a notice on your first visit. If we start using analytics or other cookies that are not strictly necessary, we will update this Policy and ask for your consent before using them.