Personal information

Who we are

The capital group of the Mint comprises the following companies: Mennica Polska S.A., Mennica Polska Spółka Akcyjna Tower SKA, Mennica Ochrona Sp. z o.o., Mennica Polska Spółka Polska S.K.A.

More information about particular companies of the Group is available online at: mennica.com.pl/o-nas/grupa-kapitalowa

The dominant company of the Group is Mennica Polska S.A. with its registered office in Warsaw, address: ul. Ciasna 6, 00-232 Warszawa, Tax Identification Number (NIP): 527-00-23-255.

Personal data controller

The personal data controller, being a company of the Mint Group, shall be identified in each case, upon collecting personal data. Remaining companies of the Group may act as the processor if justified by the purposes of the processing or for other reasons specified below.

What are the bases as well as the purposes of the collection and the processing of personal data?

We process personal data on the basis of provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council pertaining to the processing of personal data (“GDPR”). The full text of this Regulation in Polish is available at: https://eur-lex.europa.eu/legal-content/PL/TXT/?uri=CELEX%3A32016R0679.

Depending on the specific circumstances of the collection of personal data, we process personal data for the following purposes:

1) Communication with clients

We process data for the purposes of communication initiated by the client or a potential client in any communication channel (including: email, telephone, social media) – which means legitimate interests pursued by the controller (point (f) of Article 6(1) of the GDPR) involving responding to the correspondence addressed to the controller.

2) Performance of contracts concluded with clients and steps taken at the request of clients prior to entering into a contract

We process data for the purposes of the performance of contracts concluded with our clients and pertaining, for instance, to the sale of investment or collector products offered by us, sale of public transport tickets, provision of account functionalities in our online store (point (b) of Article 6(1) of the GDPR), which involves both the performance of a given contract and our service provided by us in relation thereto, such as examination of complaints or provision of services; we also process data in order to take steps at the request of the client prior to entering into a given contract (point (b) of Article 6(1) of the GDPR), e.g. when the client contacts us and asks for the presentation of our offer, using the contact form.

3) Performance of contracts concluded with business partners

We process data for the purposes of the performance of contracts concluded with our business partners with whom we cooperate as part of our business activities, which involves, e.g. purchase of products manufactured by them or use of their service (point (b) of Article 6(1) of the GDPR).

4) Maintenance of contact with business partners and their employees

We process data for the purposes of contacting or maintenance of contact with employees and collaborators authorised by our business partners for the purposes of performance of contracts concluded with them – which means legitimate interests pursued by the controller (point (f) of Article 6(1) of the GDPR) involving the proper and effective performance of contracts.

5) Marketing of own products and services

We process data for the purposes of marketing of own products or services – in various forms – including by telephone or email, as well as presentation of marketing contact on a terminal device of a potential client – which means legitimate interests pursued by the controller (point (f) of Article 6(1) of the GDPR).

6) Compliance of legal obligations to which the controller is subject

We process data for the purposes of compliance with legal obligations to which we are subject, e.g. based on regulations on counteracting money laundering, tax regulations, including regulations on keeping the register of purchasers of investment gold, or based on consumer law (point (c) of Article 6(1) of the GDPR).

7) Establishment, exercise and defence of legal claims

We process data for the purposes of the establishment and exercise of legal claims to which we are entitled, as well as for the purposes of defence of third parties’ legal claims, as well as for evidence purposes, in case of a potential inspection by authorised state authorities, which means a legitimate interest pursued by the controller (point (f) Article 6(1) of the GDPR).

8) Video monitoring

We process data by using video monitoring in our stationary stores, as well as in our manufacturing plant for the purposes of people and property protection – which means a legitimate interests pursued by the controller (point (f) Article 6(1) of the GDPR).

9) Other instances

We process data in relation to business activities conducted also in other instances, e.g. in relation to the establishment and use of business contacts at business meetings, industry events, etc., including by exchanging business card within the aforementioned scope – in order to establish and maintain business contacts – which means legitimate interests pursued by the controller (point (f) of Article 6(1) of the GDPR) involving the establishment and maintenance of the business contact network.

What personal data do we process?

We process personal data related to the business activities of the Group, including especially in relation to sales of products or provision of services. This may include the following categories of personal data: identification details (e.g. first name and surname, company name), contact details, delivery address, details of contact persons or person appointed to collect the goods, IP number used for the purposes of the client registration or logging into the account, ticket number, bank account number.

How long will we process personal data?

Personal data shall be processed for the whole period of cooperation or provision of services if cooperation takes place or services are provided on a regular basis. If data are processed on the basis of the client’s decision in the form of consent, e.g. by registration for a newsletter or expressing interest in our publication, data shall be processed until this consent is withdrawn. After the cooperation ends, data shall be processed for a period required by legal regulations or until the limitation of claims related to previous cooperation, or for a period for which data can be required for evidence purposes in case of an inspection by authorised state authorities. In principle, the period of processing of data after the termination or expiry of a contract shall be 6 years of the end of the calendar year in which the contact was terminated or expired.

To whom personal data are transferred and why?

Personal data collected by particular companies of the Group shall be transferred to Mennica Polska S.A., which is due to centralisation of business and management processes and sharing of administrative and IT resources. It may happen that Mennica Polska S.A. entrusts personal data to a company of the Group if it is justified by the need to properly perform a contract.

Moreover, we transfer some data to entities performing certain works for the Group – e.g. IT services, technical services, reporting and analytical services, verification and audit services or legal services.

Notwithstanding the foregoing, data can be transferred to public entities if it is required by applicable legal regulations. Such a transfer takes place in a way and within the scope described in these regulations.

In case of obtaining separate consent, some data (especially contact details, such as email address or telephone number) can be transferred to third parties cooperating with the Mint Group, for marketing purposes.

Cookies

We use cookies and similar technologies for marketing purposes, especially to establish marketing profiles and deliver personalised advertising to potential clients. Moreover, we use cookies and similar technologies to facilitate the use of our website, as well as for the purposes of analyses of activities of the website users and their preferences as to the website content, in order to improve our website. Personal data collected using cookies and similar technologies are processed for the same purposes. Terms and conditions of storage of and access to cookies can be changed at any time, in settings of the user’s web browser. When using our website without modifying these settings, a user of a terminal device (e.g. a smartphone or a computer) grants their consent to placing cookies and other similar technologies on this device and to using information, including personal data, collected in this way, while a modification of settings by deactivating cookies is equivalent to withdrawing this consent. Detailed information about cookies and their use is available at https://inwestycje.mennica.com.pl/en/cookies/.

Information about rights of persons whose data we process

Each person whose data we process:

1. shall have the right to request from us confirmation as to whether or not personal data concerning them are being processed by us, and, where that is the case, access to personal data concerning them;

2.shall have the right to request the rectification of personal data concerning them;

3.shall have the right to request restriction of processing of their data – including ceasing their profiling or making decisions based on profiling;

4.may, at any time, request us to cease the processing of their data by us and by entities to whom we transferred these data (exercise of so-called “right to be forgotten”);

5.shall have the right to object to the processing of data by us for marketing purposes;

6.shall have the right to object, on grounds relating to their particular situation, to processing of their data for the purposes related to legitimate interests pursued by us;

7.shall have the right to request transmitting their data by automated means to a specified recipient – to the extent these data are processed by automated means in relation to a contract concluded or consent granted;

8.shall have the right to lodge a complaint with the President of the Office for the Protection of Personal Data (address: ul. Stawki 2, 00-193 Warszawa, https://www.uodo.gov.pl) – if they conclude that their data are processed by us in breach of the law.

In case of withdrawing the consent to the processing of data or objecting to the processing, this shall not affect the actions taken based on the consent before its withdrawal or the controller being notified of the objection.

In case of excessively repetitive requests for information presented by the same person, we may make the provision of further information conditional on prior coverage of the costs related to preparing that information.

Similarly, in case of a request to transmit personal data, where the fulfilment of this request requires us to incur financial costs, we may make the fulfilment of this request conditional on prior coverage of the costs.

Additionally, we may make the fulfilment of the aforementioned requests conditional on proving that the person making the request is actually entitled thereto (e.g. presenting a proof that the person is authorised to use email address to which the request refer – in this specific case, we will consider sending the request from this address to be such a proof).

As a result of the request to restrict the scope of the processing or the objection to the processing of data, the controller may be required to cease the provision of services or the functionality and the scope of these services may be restricted.

Data profiling and data transfer outside the EEA

None of the companies of the Group uses automated profiling of data within the meaning of the GDPR or makes automated decisions based on profiling. It may happen that the controller takes certain activities (e.g. sends marketing offers) to a group of persons selected based on their prior activities (e.g. purchase history or activities on the website) or based on geographical or similar criteria.

None of the companies of the Group transfers personal data in an organised manner outside the European Economic Area. Such situation may only take place due to the technical characteristics of IT solutions, e.g. based on the processing of data in so-called “cloud.” In such case, data shall be transferred only to a third country in chase of which the Commission has decided that it ensures an adequate level of protection, and in case of transferring data to the United States – only to companies participating in the Privacy Shield framework.

Video monitoring

In order to ensure safety, and in particular the protection of people and property, video monitoring with an image recording function may be installed and used in our retail outlets and in our manufacturing plant. In such case, the monitored facility shall ensure an appropriate marking or information about the installed monitoring system. Recordings from the monitoring system shall be made available only to authorised authorities in justified instances and shall be stored for no more than 30 days from the moment of recording, excluding situations when, due to the circumstances, the recording is retained as evidence – in such case, it shall be kept until the final resolution of the relevant proceedings in which it is used as evidence.

Information about the Data Protection Officer and contact details of the controller

The Data Protection Officer of the Mint Group is Tomasz Ciupka, legal advisor. The Data Protection Officer or employees in charge of the protection of personal data in particular companies of the Group may be contacted by email, at: [email protected].