Information Clause of MHC Mobility Sp. z o.o. for Contractors and Business Partners

Information clause of MHC Mobility Sp. z o.o. regarding the processing of personal data of representatives, proxies and persons indicated for contact and cooperation on the part of Contractors and Business Partners


Contractors and Partners and their representatives, proxies and persons designated for contact and cooperation
Data Controller Pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter “GDPR”), we inform you that:

The Controller of your personal data is MHC Mobility Sp. z o.o. with its registered office in Warsaw, address: ul. Franciszka Klimczaka 1, 02-797 Warsaw, entered in the National Court Register by the District Court in Warsaw, 13th Commercial Division of the National Court Register under KRS number: 0000242025, NIP: 1181808573, (hereinafter referred to as the “Controller” or “MHC Mobility”).
Contact details – Data Protection Officer A Data Protection Officer has been appointed at MHC Mobility, with whom you may contact regarding the protection of your personal data and in order to exercise your rights under the GDPR at the email address: iodo@mhcmobility.pl or in writing to the registered office address of MHC Mobility.
Purposes and legal basis of processing

Your personal data may be processed by MHC Mobility for the purposes of:

  1. taking steps aimed at concluding and performing a contract with the entity you represent or work for, pursuant to Art. 6(1)(b–c) GDPR;
  2. exercising rights arising from representation (including power of attorney), pursuant to Art. 6(1)(b–c) GDPR;
  3. carrying out activities arising from generally applicable law, pursuant to Art. 6(1)(c–e) GDPR;
  4. carrying out activities falling within the scope of the Controller’s legitimate interest, in particular:
    – conducting direct marketing of the Controller’s own products and services (including profiling) – pursuant to Art. 6(1)(a) or (c) GDPR in connection with Art. 6(1)(f) GDPR;
    – fulfilling obligations arising from internal policies and procedures, codes of conduct and reporting obligations imposed by Mitsubishi HC Capital Group – pursuant to Art. 6(1)(f) GDPR;
    – handling complaints, requests and appeals – pursuant to Art. 6(1)(b–c) and (f) GDPR;
    – establishing, pursuing and defending claims – pursuant to Art. 6(1)(f) GDPR;
    – conducting statistical research and analyses enabling the summarisation of the results of undertaken activities – pursuant to Art. 6(1)(f) GDPR;
    – processing data for archival and evidentiary purposes – pursuant to Art. 6(1)(f) GDPR.

In the case of processing personal data for other purposes, we will provide you with a separate information clause. Detailed information may be obtained by contacting the MHC Mobility Data Protection Officer. Information on Mitsubishi HC Capital Group is available on the MHC Mobility website https://mhcmobility.pl/o-nas.

Retention period

The retention period of personal data depends on the purposes for which the data was collected and on legal provisions requiring their retention. Your personal data will be processed by MHC Mobility for the period of:

  1. the duration of the contract concluded with MHC Mobility, and after its termination, in connection with MHC Mobility’s obligations arising from generally applicable law;
  2. in the case of handling requests, inquiries, complaints and claims – for the period necessary to respond to the matter. After this period, we will continue processing your data if required by law, e.g. to document how the request of the data subject was handled or for the limitation period of claims;
  3. where the basis for processing is your consent – until such consent is withdrawn or until a request for erasure of personal data is received;
  4. in the case of data processing for direct marketing of the Controller’s own products and services – until you object to such processing.

Detailed information on retention periods can be obtained by contacting the MHC Mobility Data Protection Officer.

Categories of personal data (applies to data not obtained directly from the data subject)

Unless you have provided your data yourself, MHC Mobility has obtained your personal data from the Contractor/Partner in connection with the performance of a contract concluded with the entity you represent, in the following scope: identification data (e.g. name, surname, job title, tax number (NIP) in the case of sole traders), contact data (email address, telephone number).

Recipients of data

Your personal data may be disclosed by MHC Mobility to:

  1. public authorities, including courts, if required by law or necessary to pursue or defend against claims;
  2. MHC Mobility’s professional advisors, including tax, accounting or legal advisors;
  3. suppliers acting on behalf of MHC Mobility: IT service providers, accounting systems providers, analytical services, courier services, security services;
  4. banks and financial institutions providing services to MHC Mobility;
  5. entities within the Mitsubishi HC Capital Group, in connection with preventing fraud and abuse, effective risk management and reporting obligations, and compliance with corporate rules;
  6. entities cooperating with MHC Mobility in order to pursue the Controller’s legitimate interests.
Rights of the data subject

In connection with the processing of your personal data by MHC Mobility as Controller, you are entitled to:

  1. the right of access to personal data;
  2. the right to rectify personal data;
  3. the right to erase personal data (“right to be forgotten”);
  4. the right to restrict processing of personal data;
  5. the right to data portability to another controller;
  6. the right to object to processing, including for direct marketing purposes;
  7. the right to withdraw consent if MHC Mobility processes your personal data on the basis of consent – at any time and in any manner, without affecting the lawfulness of processing based on consent before its withdrawal;
  8. the right to lodge a complaint with the President of the Personal Data Protection Office if you believe that the processing of your personal data violates GDPR provisions.
Source of personal data
  1. Your personal data may be obtained directly by MHC Mobility from the data subjects, i.e. from a representative or proxy;
  2. If you have not provided your data directly, we have obtained it from your employer or from the entity on whose behalf you act, in connection with concluding and performing a contract with MHC Mobility.
Voluntary provision of personal data

Providing personal data in connection with actions aimed at concluding a contract, and subsequently its performance, is voluntary. Failure to provide the data will make it impossible to conclude and perform such a contract.

Automated decision-making, including profiling

Your personal data will not be processed in an automated manner, including profiling.

Transfer of data outside the EEA
  1. Since MHC Mobility is part of the international Mitsubishi HC Capital Inc. group, the Controller may transfer personal data to a third country where companies belonging to the group are located, in particular Japan and the United Kingdom of Great Britain and Northern Ireland.
  2. Japan and the United Kingdom of Great Britain and Northern Ireland are countries for which the European Commission has recognised an adequate level of data protection.
  3. In other cases, your personal data will generally not be transferred outside the European Economic Area. In exceptional cases, should such transfer occur, the Controller will comply with the safeguards and principles set out in Articles 44–49 GDPR.

Detailed information regarding the safeguards applied in such cases may be obtained by contacting MHC Mobility.

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