1. Scope of data

KUKE Finance S.A. processes personal data in the following scope: identification data (first name, last name, job title, name of the business entity, NIP, REGON, PESEL, ID card series and number or passport number), contact data (telephone number, e-mail address), correspondence data (residential address, registered address, correspondence address), and financial data (bank account number).

2. Data Controller

The Data Controller is KUKE Finance S.A., with its registered office in Warsaw (00-025), ul. Krucza 50, entered into the Register of Entrepreneurs maintained by the District Court for the Capital City of Warsaw, 12th Commercial Division, under KRS number   0000501348, NIP 525 258 12 00, REGON 147130332.

3. Contact with the Data Protection Officer of KUKE Finance S.A.

Any person may contact the Data Protection Officer of KUKE Finance S.A. in writing at the company’s registered address (KUKE Finance S.A., ul. Krucza 50, 00-025 Warsaw, with the note “Data Protection Officer”) or electronically at: iod@kuke-finance.pl.

4. Purposes and legal bases of processing

Personal data are processed for the following purposes:

a) performance of the factoring agreement concluded between KUKE Finance S.A. and the Seller in relation to the assignment of receivables (Article 6(1)(f) GDPR);

b) settlement of the assigned receivables under tax and accounting regulations (Article 6(1)(c) GDPR);

c) internal administrative purposes of KUKE Finance S.A., including internal statistics and reporting within KUKE Finance S.A. and within the KUKE Group, constituting the legitimate interest of KUKE Finance S.A. (Article 6(1)(f) GDPR);

d) prevention of criminal activity in the area of factoring operations (Article 6(1)(f) GDPR);

e) establishment, exercise, or defence of legal claims, constituting the legitimate interest of KUKE Finance S.A. (Article 6(1)(f) GDPR);

f) handling complaints, if submitted, regarding the manner in which the Debtor is serviced in connection with the assignment of receivables (Article 6(1)(b) GDPR);

g) handling complaints, if submitted, regarding the quality of services provided by KUKE Finance S.A. and the manner in which KUKE Finance S.A.’s employees provide customer service (Article 6(1)(f) GDPR).

5. Data recipients

Recipients of personal data may include: entities providing services to KUKE Finance S.A. that require access to personal data for which KUKE Finance S.A. is the Data Controller (under data processing agreements), including entities cooperating in the area of IT services, market research, entities supporting the settlement of agreements, debt collection companies, document archiving service providers, administrative and office service providers, advisory and consulting firms, as well as the Polish Bank Association (Związek Banków Polskich – https://kuke-finance.pl/polityka-prywatnosci/), KUKE S.A., law firms, audit service providers, and entities authorised under applicable law.

6. Retention period

Data processed on the basis of the legitimate interest of KUKE Finance S.A. are stored until the legitimate interest of KUKE Finance S.A. that constitutes the basis for such processing have been fulfilled or until an objection is raised. Data processed for other purposes are stored for no longer than 5 years from the end of the year in which the factoring agreement between KUKE Finance S.A. and the Seller was terminated and settled.

7. Rights of the data subject

The data subject has the right to access their personal data, the right to rectify, erase, or restrict the processing of their data, the right to data portability, the right to object to the processing of personal data, and the right to lodge a complaint with the President of the Personal Data Protection Office.

8. Right to object

The data subject has the right to object at any time to the processing of personal data based on the legitimate interest described above. KUKE Finance S.A. will cease processing the data for these purposes unless it demonstrates compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the data subject, or unless the data are necessary for the establishment, exercise, or defence of legal claims.

9. Source of data

Personal data were obtained by KUKE Finance S.A. from the Seller, who is your contracting party and with whom KUKE Finance S.A. concluded a factoring agreement under which the receivables were assigned.

10. Automated decision-making

Personal data are not subject to automated decision-making, including profiling related to automated decision-making.