All data subjects whose personal data is collected, in line with the requirements of the GDPR.
2.1 The Assigned Data Protection Officer is responsible for ensuring that this notice is made available to data subjects prior to Dressler Consulting collecting/processing their personal data.
2.2 All Employees/Staff of Dressler Consulting who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.
3. Privacy notice
3.1 Who are we?
Dressler Consulting is a US-based multinational company with offices in the United States, Poland and Ukraine. Our goal is to provide clients with strategic business planning and integration services with an emphasis on infrastructure, data communications, and Internet-related technologies.
Our assigned Data Protection Officer and data protection representative can be contacted directly via:
- Website: https://dresslerconsulting.com/
- Contact: Data Protection Officer
- Email: firstname.lastname@example.org
- Tel: +38 (066) 382 30 11; +38 (098) 013 85 35
- Address: 14 Soborna Str., Lviv 79008 Ukraine.
By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. Consent is required for Dressler Consulting to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.
You may withdraw consent at any time by contacting us at the details provided or in line with Withdrawal of Consent Procedure.
Dressler Consulting will not pass on your personal data to third parties without first obtaining your consent. We do not share your personal data without first obtaining your consent
3.4 Retention period
3.5 Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
- Right to judicial review: in the event that Dressler Consulting refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.
All of the above requests will be forwarded on should there be a third party involved (if stated in 3.5 above) in the processing of your personal data.
In the event that you wish to make a complaint about how your personal data is being processed by Dressler Consulting (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Dressler Consulting data protection representative, the assigned Data Protection Officer, details as in 3.1.
You can contact the supervisory authority, UODO (Urzad Ochrony Danych Osobowych), through the contact form that can be found on the website: https://www.uodo.gov.pl/
3.7 Privacy statement
4. Online privacy statement
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as: “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
How we use your information
This privacy notice tells you how we, Dressler Consulting, will collect and use your personal data. We acquire and use information relating to commercial organisations and individuals for a variety of reasons:
- Delivery of our services
- Legal obligations
- Marketing purposes
If you are requested to provide us with personal information you can of course refuse. If you choose not to provide the data that we require to provide our services then we may not be able to deliver that service for you.
The personal data that we would like to collect from you may include the following:
Contact data: We will request your full name, postal address, phone number and e-mail address.
Special category data: We may request on occasion such data about you that may be necessary to facilitate the execution of our services. This maybe data such as your current health for a vulnerability assessment.
Payment data: Where it is necessary to process your payment, if you are repaying debt or for payments of services supplied to you, then sensitive information, such as your debit card number, security code and cardholders address maybe requested but not stored by us. The payment is processed by our staff using secure processing websites with secure links operated by our approved card merchant service providers. The information is not stored on our systems or held with any of our personnel.
Business and relationships: We may collect such personal information that you provide to us relating to your contacts and business relationships.
Content: We may collect the content of any data files and communications that you may send us for the purposes of carrying out your instruction, together with any relevant physical documents that you may give us as well, when these are necessary to provide you with the offered service. Data we collect may include:
- address, subject line and body of an email,
- video and/or audio recording of a video message
- site photographs
- written content of a text, similar app or other content of an instant message
- relevant social media message
We may also collect information that you provide us with regards to client feedback for services provided. This information will be retained in line with our retention policy.
The personal data we collect will be used for the following purposes:
- To carry out our business activities
- To comply with legal and regulatory obligations and requirements
- To enforce using the appropriate legal process
- Update existing information
- Manage our products and services
- Monitor and keep records of communications
- To improve the operations of our business where possible
Our legal basis for processing the personal data:
- To provide products and service
- Legitimate interests
- To comply with legal and regulatory obligations and requirements
- Vulnerability assessments
- Public interest matters
Any legitimate interests pursued by us, or third parties we use, are as follows: Develop business partnerships To comply with legal and regulatory obligations and requirements
The special categories of personal data concerned are:
- Health information – if it relates to: o vulnerability as provided within ‘The Taking Control of Goods Regulations 2013’
- client requirements for a vulnerability assessment before legitimate removal of trespassers
We collect all forms of data by means of verbal and written communication as well as through the contact icon via ‘contact us’ on our website.
Why does Dressler Consulting need to collect and store personal data?
In order for us to provide you with the services we offer we need to collect personal data for:
- General information processing: though we do not undertake automated decision making or profiling of personal data.
- Legitimate Business requirements.
- Perform contractual and payment obligations
- Meet legal obligations and requirements
In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy. In terms of being contacted for marketing purposes Dressler Consulting would contact you for additional consent.
Will Dressler Consulting share my personal data with anyone else?
We may pass your personal data on to third-party service providers contracted to Dressler Consulting in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Dressler Consulting procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.
How will Dressler Consulting use the personal data it collects about me?
Dressler Consulting will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Dressler Consulting is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
Under what circumstances will Dressler Consulting contact me?
Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
Can I find out the personal data that the organisation holds about me?
Dressler Consulting at your request, can confirm what information we hold about you and how it is processed. If Dressler Consulting does hold personal data about you, you can request the following information:
- Identity the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
- Contact details of the data protection officer, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of Dressler Consulting or a third party, information about those interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
- How long the data will be stored.
- Details of your rights to correct, erase, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
How to lodge a complaint with the supervisory authority
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
What forms of ID will I need to provide in order to access this?
Dressler Consulting accepts the following forms of ID when information on your personal data is requested: Passport, driving licence, birth certificate, utility bill (from last 3 months), etc.
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Cookies that we do and do not use
Cookies used by our service providers
These cookies are used to store information, such as what time your current visit occurred, whether you have been to the site before, and what site referred you to the web page.
These cookies contain no personally identifiable information (PII) but they will use your computers IP address to know from where in the world you are accessing the internet.
Google stores the information collected by these cookies on servers in the United States of America. Google may transfer this information to third parties where required to do so by law, or where such third parties process information on Google’s behalf.
Cookies used by our service providers
Website Visitor Tracking Opt-out
We use Facebook Pixel to track conversions on our website. Conversion tracking helps us measure the return on investment of Facebook Ads by reporting on actions people take after viewing those ads. We create pixels that track conversions, add them to the pages of website where the conversions will happen, and then track these conversions back to ads we are running on Facebook.
What data does the Facebook pixel collect?
The Facebook pixel receives these types of data:
Http Headers – Anything present in HTTP headers. HTTP Headers are a standard web protocol sent between any browser request and any server on the internet. HTTP Headers include IP addresses, information about the web browser, page location, document, referrer and person using the website.
Pixel-specific Data – Includes Pixel ID and the Facebook Cookie.
Button Click Data – Includes any buttons clicked by site visitors, the labels of those buttons and any pages visited as a result of the button clicks.
Form Field Names – Includes website field names like ‘email’, ‘address’.
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorerdelete-manage-cookies (Internet Explorer);
e) https://support.apple.com/kb/PH21411 (Safari); and
Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you may not be able to use all of the features on our website.
Summary of Changes Reference
Created according to GDPR Regulation requirements