INTRODUCTION
On the course of our activities, we collect and process your personal data in order to provide you with the best service, advice, and solutions, and to fulfil our contracts with you. Moreover, by collecting your data, we comply with our legal obligations regarding the collection and retention of personal data.
This Privacy Policy is applicable when you visit our Website: www.complium.com, you contact us via the contact forms, or you contact us using the contact details available on the Website, our social media accounts or you provide us with your details so that we can contact you about a specific matter or send you a Newsletter.
WHO COLLECTS YOUR DATA?
Your data is collected and processed by the Controller: Complium Poland sp. z o.o., with its registered address in Warsaw, Poland, ul. Solipska 3/5, 02-482, entered into the entrepreneur register under KRS number: 0001089880 (hereinafter referred to as “Complium”, “we/us”).
We protect your data and privacy in all ways provided by applicable law.
The information contained in this Privacy Policy applies to the personal data of natural persons, but not to the data of companies or other legal entities or institutions. The information also applies to the personal data of all natural persons engaged in vocational and professional activities (e.g. employees of a company or organisation). If you communicate with us as a person related to a Business Customer, we will also register and use your personal data.
WHY DO WE COLLECT AND USE YOUR PERSONAL DATA? PURPOSE OF THE DATA COLLECTION
Complium collects processes personal data in order to:
- respond to inquiries you sent to us through the contact forms, our social media accounts or contact details provided on our Website or to reach out to you as per your requests via contact forms (on the basis of Article 6(1)(f) GDPR),
- provide you with the Newsletter mentioned in the section VI of the Terms and Conditions (on the basis of Article 6(1)(b) GDPR),
- prepare service offers at your request (on the basis of Article 6(1)(b) GDPR),
- enter into contracts, provide services to and ensure the fulfilment of obligations that you require from us (on the basis of Article 6(1)(b) GDPR),
- clarify under which conditions to provide services and sell goods (on the basis of Article 6(1)(b) GDPR),
- conduct customer satisfaction surveys (based on t Article 6(1)(f) GDPR),
- provide you with convenience services and deliver announcements per your request (based on the Article 6(1)(b) GDPR),
- comply with legal obligations binding us as the data Controller (including data storage and backup (based on the Article 6(1)(b) GDPR);
We collect the personal data directly from you or by monitoring your activities, such as when you:
- fill out applications or other forms to receive services;
- submit documents to us on paper or via electronic correspondence.
We will only retain your data for as long as it is necessary for the purpose for which we collected and used your data, unless otherwise provided by applicable law, or as follows:
- We retain the personal data for up to three years from the beginning of the year following the end of your communication thread;
- We retain accounting data for up to seven years from the end of the financial year when the transaction was recorded in our accounting system.
After the expiry of the Personal Data retention period, we may retain your Personal Data for longer than is necessary to comply with a legal obligation or requirement, to resolve legal disputes, or to ensure the performance of a contract with us.
At the end of the personal data retention period or if the legal basis related to the purpose of processing personal data ceases to exist, we may retain materials containing your Personal Data in backup systems, from which they will be deleted at the end of the backup cycle. During the backup period, we implement appropriate measures to ensure the security of backed up materials. Backed up materials are decommissioned, not processed for any purpose, and erased as soon as possible, i.e. at the end of the backup cycle.
This means that we collect and use your personal data if:
- You have concluded a contract with us or are considering concluding one (on the basis of Article 6(1)(b) or Article 6(1)(f) GDPR);
- You have given us your consent to use your personal data;
- It is necessary for the legitimate interests of Complium, including to prevent legal violations or damage, to strengthen the security of IT systems or payments, or for direct marketing purposes. We will only do this if our respective interest clearly outweighs your interest not to process your personal data (Article 6(1)(f) GDPR);
- If you communicate with us as a person related to our Business Customer, then depending on the content and scope of our communication, we may process your personal data for the following purposes:
- to perform our contractual obligations and to provide services to the Customers (on the basis of the Article 6(1)(b) GDPR);
- to comply with the applicable legislation (on the basis of the Article 6(1)(f) GDPR);
- for administrative purposes, including securing, supporting and maintaining our systems, platforms and other digital applications (on the basis of the Article 6(1)(f) GDPR);
- to carry out the necessary checks to prevent crimes )on the basis of the Article 6(1)(f) GDPR).
Special categories of personal data
In its economic activities, Complium does not collect personal data such as racial or ethnic origin, political views, religious or philosophical beliefs or trade union membership, genetic data, biometric data used for the unique identification of a natural person, health data or data about a natural person’s sexual life and sexual orientation.
Complium may collect special categories of personal data in its economic activities only if we need them in order to provide you with service-related advice or to provide you with a service. For the processing of special categories of personal data, we will ask for your explicit consent, unless the law gives us the right to process special categories of personal data without your consent (e.g. to legally enforce our claims).
We may also collect other personal information if it is necessary to provide you with specific services or if required to do so by law.
Our ability to advise you and provide you with the best solutions depends to a large extent on how well we know you. Therefore, it is important that you provide us with correct and accurate information and keep us informed of any changes.
THIRD PARTIES AND YOUR PERSONAL DATA
Personal data received from third parties
We register and use personal data obtained from third parties, such as:
- from a national register, such as the business register, the population register or another public source or register. We collect and use this data, for example, to verify the accuracy of the data;
- From the business partners of Complium , if we have your consent or if it is permitted by legislation.
Third parties to whom we disclose your personal data
In certain cases, we may disclose your personal data to third parties if:
- you have asked us to do so;
- it is required by law;
- you have given your prior consent;
With your consent, when transferring personal data to data processors located in third countries (i.e. outside the European Union and the European Economic Area), we ensure the protection of your rights and that, in the event of such data transfer, your personal data is maintained at a level of protection that meets the conditions approved by the European Commission.
PROFILING AND AUTOMATED DECISIONS
Profiling
Complium OÜ does not perform automated processing of your personal data, the purpose of which would be to evaluate, analyse and forecast certain personal aspects related to a natural person, in particular such aspects related to the relevant natural person’s work performance, economic situation, health, personal preferences, interests, reliability, behaviour, location or movement.
Automated decision-making
Complium OÜ does not perform automated processing of your personal data, the purpose of which would be to evaluate your personal data in order to take decisions that may restrict your rights and freedoms.
YOUR RIGHTS
Accessing your personal data
You can access the personal data collected and used about you, the sources thereof and the purposes of their use. You will be able to obtain information about how long we retain your data and to whom and to what extent we transmit it. Your right to access your personal data may be limited by applicable legislation, the rights of others to ensure their privacy, and the needs of our operations. Our know-how, trade secrets, internal assessments and materials may also be part of the information that cannot be accessed.
Right to state objections
You have the right to raise objections to the processing of your personal data, including if we rely on our legitimate interests in processing the data.
You also have the right to object to the use of your personal data for direct marketing.
Rectification or erasure of data
If your data is incorrect, incomplete or irrelevant, you have the right to request the rectification or erasure of the data, taking into account the restrictions arising from applicable legislation and the rights related to data processing.
Restriction of data use
If you find that the information we have collected about you is incorrect, or if you have objected to the use of the data, you may request that we restrict the use of the data to retention only. The use is limited to retention only until it is possible to establish the accuracy of the data or to verify that our legitimate interests outweigh your interests.
If you have the right to request the erasure of data, you can instead request that we limit our use of the data to the retention only. If we need the data we collect about you only to enforce or defend legal claims, you may request that the data not be used for purposes other than retaining. However, we may have the right to use the data in a different way if this is necessary to enforce the claims or if you have given your consent.
Withdrawal of consent
If the use of data requires your consent, you can withdraw this consent at any time. Please note that if you withdraw your consent, we may not be able to provide you with certain services. We will also continue to use your personal data, for example, to perform a contract with you or in accordance with legal requirements.
Data portability
If we use the data on the basis of your consent or agreement and the data processing is automated, you have the right to receive a copy of the data you have provided in an electronic machine-readable format.
Time of realisation of the rights, summarised in a table
| Rights | Realisation |
| Right to consent to data processing | Consent is requested immediately upon data collection (if the data is collected directly from you) or within one month (if the data is collected from a third party) |
| Right to withdraw consent to data processing | Instantly, without unreasonable delay |
| Right to access data | Within one month of the application |
| Right to rectification of data | Within one month of the application |
| Right to erasure of data, “to be forgotten” | Instantly, without unreasonable delay |
| Right to restriction of data processing | Instantly, without unreasonable delay |
| Right to data portability | According to the submitted application |
| Right to state objections | Proceedings shall be initiated on receipt of an objection |
| Rights related to automated processing or profiling. | According to the submitted application |
USE OF COOKIES
Complium uses cookies on its websites. Cookies are small text files that are downloaded to your device when you visit our website.
By continuing to use our website, you consent to the use of cookies in accordance with the rules of these terms and conditions.
If you do not agree to the use of cookies, you have the option to configure your browser so that your computer does not store cookies. In this case, however, we cannot guarantee that all functions on our site will work correctly for you. More information on managing and disabling cookies can be found on the website http://www.allaboutcookies.org/
With the help of cookies, we can improve the quality of services. We use cookies to collect statistical data, to remember the preferences of the visitor of the page, to serve advertisements.
When visiting Complium websites, our data analysis and advertising partners (Google Analytics, Facebook, YouTube, etc.) can also store cookies on your device.
SECURITY OF PERSONAL DATA PROCESSING
Complium stores personal data only for the strictly minimum necessary time. Personal data with an expired retention period will be destroyed using best practices.
Complium ensures the protection and appropriate security of personal data, including against unauthorised or illegal processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
Access to personal data is granted only to processors who have the necessary right to do so and only to the extent necessary to achieve the purpose arising from the legitimate interest.
Complium confirms that it complies with the requirements in force in the EU regarding the protection of personal data. Complium makes every effort to protect personal data. We process personal data only for specific and legitimate purposes and only to the extent necessary for such purpose. We also demand the same values and adherence to our personal data processing rules from our cooperation partners.
In the event of any incident involving personal data, Complium will take all necessary measures to alleviate the consequences and to mitigate similar risks in the future.
TERMS OF USE OF NOTIFICATIONS
Notifications are offers sent to the subscribers through communication channels that, in the opinion of Complium, may be of interest to the subscribers.
You can opt out of notifications at any time. To unsubscribe from the newsletter, you can click on the link at the end of the letter. To opt out of other notifications, please contact [email protected] or contact us by sending a letter to our office in Warsaw, Poland: ul. Solipska 3/5, 02-482.
CONTACT INFORMATION AND SUBMISSION OF COMPLAINTS
If you have any questions regarding your rights in relation to the processing of your personal data, or if you have any questions about how we collect and use personal data or if you are not satisfied with the way we process your personal data, please contact us:
Warsaw, Poland, ul. Solipska 3/5, 02-482
Email: [email protected]
If your data protection contact with Complium has not produced a satisfactory result, you have the right to submit a relevant dispute with Complium or file a complaint with a supervisory authority:
Urząd Ochrony Danych Osobowych
ul. Stanisława Moniuszki 1A, 00-014 Warszawa
website: https://uodo.gov.pl/pl
Last updated 19.02.2026