Website Privacy policy

Website privacy policy.

Lagardere Duty Free website.

Introduction

Lagardere Duty Free sp. z o.o. (hereinafter: LDF) treats personal data protection with the utmost care. In this context, our goal is also to properly inform you about matters related to the processing of personal data, especially regarding the content of the new provisions on the personal data protection, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27.04.2016. on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (“GDPR”). For this reason, in this document we inform you about the legal grounds for processing personal data, how to collect and use them, as well as the rights of data subjects.

What is personal data and what does processing mean?

Personal data means any information about an identified or identifiable natural person. The processing of personal data is any activity on personal data, regardless of whether it is carried out in an automated manner or not, e.g. collecting, storing, recording, organizing, modifying, viewing, using, sharing, limiting, deleting or destroying. LDF processes personal data for various purposes, and depending on the purpose, different collection methods, legal grounds for processing, use, disclosure, and storage periods may apply.

When does this Privacy Policy apply?

This privacy policy applies to all cases where LDF is the controller of personal data and therefore processes personal data. This applies to cases in which LDF processes personal data obtained directly from the data subject, as well as cases in which we obtained personal data from other sources. LDF performs its information obligations in both of the above cases, as specified in art. 13 and art. 14 of GDPR in accordance with these provisions. Below are the full LDF data as the personal data controller:

Lagardere Duty Free Sp. z o.o. seated in: ul. Aleje Jerozolimskie 174, 02-486 Warsaw, entered in the Register of Entrepreneurs kept by the District Court for the Capital City of Warsaw, XII Commercial Division of the National Court Register, under KRS number 0000257014, NIP 522 28 17 394.

The company has appointed a Personal Data Protection Inspector who can be contacted at the address given above or by e-mail to the following address: iodo@lagardere-tr.pl

How, based on what legal basis and what type of personal data is LDF processing the data?

LDF processes personal data by making every effort regarding the scope and method of legal processing of personal data, as well as the purposes for which it processes.

Processing of personal data of visitors to websites administrated by Lagardere Duty Free.

General information

Natural persons visiting LDF websites, called “Websites”, have control over the personal data they provide to us. Websites limit the collection and use of information about their users to the minimum necessary to provide services to them at the desired level, pursuant to art. 18 of the Act of July 18, 2002 on the provision of electronic services.

Cookies

Cookies are small text files saved on the user’s computer or other mobile device while he is using websites. These files are intended, among others for usage of various functions provided on a given website or confirming that a given user has seen specific content from a given website.

LDF websites use “cookies”.

The installation of “cookies” is necessary for the proper provision of services on the website. The “cookies” files contain information necessary for the proper functioning of the website, and also provide the opportunity to compile general statistics of website visits. This information does not record specific personal data of the user, but is used to compile statistics on the use of the website.

The site uses session and persistent “cookies”

      1. “Session” cookies are temporary files that are stored on the user’s end device until logging out (leaving the site).

      2. Persistent cookies are stored on the User’s device for the time specified in the cookie file parameters or until they are deleted by the User.

LDF websites also use their own cookies to better understand how users interact with the content of the page.

The user has the right to decide on the access of “cookies” to his computer by first selecting them in his browser window. Detailed information about the possibilities and handling of cookies is available in the software (web browser) settings.

Types of personal data processed, legal basis and what type of personal data is processed by LDF?

LDF takes special care to protect the interests of data subjects, and in particular ensures that the data it collects are:

      1. processed in accordance with the law,

      2. collected for designated purposes and not subjected to further processing incompatible with those purposes,

      3. factually correct and adequate in relation to the purposes for which they are processed and stored in a form that enables identification of persons to whom they relate, no longer than it is necessary to achieve the purpose of processing.

In the case of personal data processing in connection with the use of LDF Websites by the users, we may be dealing with different types of legal grounds for processing, depending on the category of personal data we process and the purpose of processing.

LDF processes personal data through our website based on:

  1. the legitimate interest of the data controller in connection with the receipt of messages by e-mail via the website. Such messages contain the username and e-mail address set, as well as additional information that the user wants to include in the message.

  2. based on consent in the event that we have asked the data subject for consent. This applies to visitors to websites administrated by LDF from natural persons who contact LDF to obtain information about the offer or to share comments regarding LDF services or products, as well as to contact in order to conclude an agreement with LDF, to obtain information about ongoing recruitment. We collect the following personal data: name and surname, e-mail address and telephone number. In particular, they can send us an email via the website. Such messages contain the username and e-mail address set, as well as additional information that the user wants to include in the message.

  3. on the basis of consent in the case of marketing and promotional purposes. We collect the following personal data: name and surname, e-mail address and telephone number,

  4. based on compliance with a legal obligation incumbent on LDF, if any. The scope of processed data results from the implemented legal provision.

  5. personal data provided by you voluntarily is treated as if you consented to their processing.

We request that you do not provide information via websites considered as specific categories of personal data (such as information on race or ethnic origin, political views, religious or philosophical beliefs, trade union membership, information about physical or mental health, genetic data, biometric data, information about sexual life or sexual orientation) and criminal past. If you provide such information for any reason, this will mean your explicit consent to us for collecting and using such information in the manner specified in this document or specified in the place where this information was disclosed.

When using the website, additional information may be downloaded, in particular: the IP address assigned to the user’s computer or the external IP address of the Internet provider, domain name, type of browser, access time, type of operating system.

Navigation data may also be collected from users, including information about links in which they choose to click or other actions taken on the website. The legal basis for this type of activity is the Controller’s legitimate interest (Article 6 (1) (f) of the GDPR), consisting in facilitating the use of electronic services and improving the functionality of these services.

Personal data will also be processed in an automated manner in the form of profiling, provided that the user agrees to it pursuant to art. 6 clause 1 (a) of GDPR. The consequence of profiling will be the assignment of a given profile to a person to make decisions about him or to analyse or predict his preferences, behaviours and attitudes.

For how long do we process personal data?

The time for which we can process personal data depends on the legal basis which is the legal condition for the processing of personal data by LDF. In LDF policies, including data retention policies, we state that we must never process personal data longer than a period stated in the abovementioned legal basis. We would like to inform you that:

1) if LDF processes personal data based on the consent, the processing period lasts until the user withdraws that consent;

2) in the event that LDF processes personal data on the basis of the legitimate interest of the data controller, the processing period lasts until the abovementioned interest (e.g. limitation period for civil law claims) or until such time as the data subject opposes further processing – in situations where such an objection is in accordance with the law;

3) in the case when LDF processes personal data because it is necessary due to applicable law, the periods of data processing for this purpose are specified in these provisions.

4) in the absence of specific legal or contractual requirements, the basic period of data storage in the case of records and other documentary evidence drawn up during the performance of the contract, is a maximum of 10 years.

When and how do we share personal data with third parties?
Do we transfer data to third countries?

We only transfer personal data to others when permitted by law. In this case, we will provide for security provisions and mechanisms to protect your data and to comply with our standards for data protection, confidentiality and security in an appropriate agreement with a third party. Such agreements are called agreements for entrusting personal data processing, and LDF has control over how and to what extent the entity entrusted with the processing of certain categories of personal data by LDF processes this data. In connection with the above, we point out that the recipients of personal data that LDF processes as a personal data controller can be:

– above mentioned entities that process the personal data under agreements for entrusting personal data processing (so-called processors)

– entities providing hosting services to LDF

– entities implementing marketing or sales campaigns for LDF

– other LDF subcontractors providing software delivery services, software maintenance services or equipment used by LDF, as well as suppliers of goods that we use

– debt collection companies

(we transfer personal data only to the extent that it is actually necessary to achieve the given purpose)

– auditors and statutory auditors, legal advisers, tax advisers

– law enforcement bodies, regulatory bodies and other public administration bodies,

(in the last two cases, we provide data only if and only to the extent that it is actually necessary and required under the mandatory provisions of law and in a manner consistent with these provisions).

Moreover, as we have pointed out earlier, LDF is part of the Lagardere Group, as a result of which certain personal data may be transferred to other companies of the Lagardere Group (LagardereTravel Retail sp. z o.o., Inflight Service sp. z o.o., Inmedio Services Poland sp. z o.o.) and the company Inmedio sp. z o.o.

Users’ personal data is stored only within the European Economic Area

What rights do data subjects have and how are they implemented?

Natural persons have specific rights regarding their personal data, and LDF as the data controller is responsible for the implementation of these rights in accordance with applicable law. For all questions and requests regarding the scope and exercise of rights, as well as to contact us just to exercise a specific right in the field of personal data protection, please contact us at the following email address:

iodo@lagardere-tr.pl . We reserve the right to exercise the following rights after positive verification of the identity of the person applying for a given activity.

Access to personal data

Individuals have the right to access data that we store as a data controller. This right can be exercised by sending an email to: iodo@lagardere-tr.pl

Change of personal data

Changes, including the update of your personal data, which WKP processes can be made by sending an email to the following email address: iodo@lagardre-tr.pl .

Withdrawal of consent

In the case of processing personal data based on consent, natural persons have the right to withdraw this consent at any time. We inform you of this almost at any time when collecting consents and allow you to withdraw your consent as easily as it was given. In the absence of other information, i.e. if we have not provided another address or contact number to withdraw consent, please send us an email to iodo@lagrdere-tr.pl .

The right to limit processing or object to the processing of personal data

Natural persons have the right to limit the processing or object to the processing of their personal data at any time, due to their special situation, unless the processing is required by law.

An individual may object to the processing of his personal data when:

  • the processing of personal data is based on a legitimate interest or for statistical purposes, and the opposition is justified by the particular situation in which it finds itself,

  • personal data is processed for the purposes of direct marketing, including being profiled for this purpose.

In turn, with regard to the request for limitation of data processing, we advise that it applies, e.g. when a person notices that their data is incorrect. Then it may request that your data be restricted for a period of time that allows us to check the data correctness.

Other rights: the right to request deletion of data and the right to transfer data

If you wish to exercise these rights, please send an email to iodo@lagardere-tr.pl

The right to delete data can be used, e.g. when the data of a natural person are no longer necessary for the purposes for which they were collected by LDF or when a natural person withdraws his consent to the processing of data by LDF. In addition, if a natural person objects to the processing of his data or if his data will be processed unlawfully. The data should also be deleted in order to fulfil the obligation arising from the provision of law.

In turn, the right to transfer data is granted when the processing of a person’s data takes place on the basis of the consent of a natural person or an agreement concluded with him and when the processing is carried out automatically.

All other questions, doubts and complaints

If you have any questions, reservations or doubts regarding the content of this Privacy Policy or the way in which we process personal data, as well as complaints regarding these issues (although we hope that you will not need to submit such complaints), please send an email along with detailed information on the complaint to iodo@lagardere-tr.pl Any complaints received will be considered and we will responded. LDF’s Personal Data Protection Inspector, e-mail address: iodo@lagardere-tr.pl

Before fulfilling the request of the data subject, we have the right to verify it.

Persons whose personal data are processed by LDF also have the right to lodge a complaint with the supervisory body, which is the President of the Office for Personal Data Protection (address: ul. Stawki 2, 00-193 Warsaw).

Contact us directly at the LDF headquarters, as well as by mail (post) or telephone contact and for this purpose we provide the following contact details:

Lagardere Duty Free sp. z o.o.

ul. Aleje Jerozolimskie 174

02-486 Warszawa

phone: 506015309; 22 5723299

The last update of this document took place on February 17, 2020.

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