Privacy Policy Czechia

Data controller:Raben Logistics Czech s.r.o.
Company ID (IČO):247 05 128
Registered office:Komerční 535, 251 01 Nupaky, Czech Republic
Website:ceskarepublika.raben-group.com
Contact:gdpr.cz@raben-group.com

 

(hereinafter “we”)


This document applies to the processing of personal data of natural persons as our customers, consignees (shipment recipients) or consignors (senders).


What will you learn in this document?

  • Who we are and why we process your personal data
  • Which personal data we process
  • Where we obtain the personal data from
  • To whom we may disclose the personal data
  • When we may transfer personal data abroad
  • How long we retain the personal data
  • What your rights are


1. Who are we and why do we process your personal data?

Raben Logistics Czech s.r.o. (hereinafter also “Raben CZ”), a member of the Raben Group, provides comprehensive logistics services and domestic and international transport of goods. The protection of personal data is very important to us; therefore, we always act in accordance with applicable laws and proven international standards.

The rules on the processing of personal data apply only to natural persons; therefore, the information below mainly applies to them. However, we make maximum efforts to protect all data we use.

In order to achieve our business objectives and ensure the highest standards of the services provided, other companies within the Raben Group may process personal data together with us as joint controllers. Detailed information on joint controllership can be found below in Appendix 1. The primary contact point for exercising data subject rights is Raben CZ, in accordance with this privacy notice.

i. Processing of personal data on the basis of a contract

This section covers processing related to the offering and provision of our services (conclusion and performance of a contract). These include in particular domestic and international road, air and sea transport services and comprehensive logistics services such as unloading and deconsolidation, collection and securing of consignments and their preparation for distribution, as well as other ancillary services (labelling, packing, etc.) and the related documentation and communication, including online services and forms (MyRaben system, Track&Trace application).

On this basis, we process personal data that are necessary to carry out the transport (identification and contact data, job position, and the content of documentation and communication you send us). Where necessary, we also process the data of other parties to the contractual relationship or other persons concerned (recipients, drivers, etc.). Without processing these data, we cannot offer or provide our services to you. Therefore, no separate consent is required for such processing. If you do not provide the required data, we will not be able to enter into a contract with you.

Where specific products or services are provided online (via the internet), we process the personal data of end users of these products and services. Please note that information about cookies and logs also applies to such processing (see section v.).

If you wish to send us an email, please note that unencrypted email messages sent over the internet are not fully protected against access by third parties.


Processing of data of carriers, drivers and contact persons

In order to secure consignments for our customers, manage the fleet, optimise transport planning and duly perform transport services, we need personal data of drivers, in particular first name and last name, identity card number or passport number, and a contact telephone number.

In order to comply with food handling safety principles, we need the data contained in medical certificates for sanitary and epidemiological purposes. In addition, in order to properly carry out the transport of ADR goods in accordance with regulations, we must have information on whether you are authorised to transport them.

In order to ensure transport and protect entrusted property, Raben may monitor the location of vehicles through a satellite navigation system (GPS device).

In connection with the above, we will process your personal data for the performance of a contract and on the basis of our legitimate interests, i.e., the proper performance of the transport service.


TLME lite application

Within this application, your personal data in the form of GPS location will be processed on the basis of your consent, which may be withdrawn at any time, in order to ensure the highest level of services provided to customers of the Raben Group (organisation of working time by determining the shortest and fastest routes required to complete transport, real-time calculation of the estimated time of arrival at the unloading location, securing property, and facilitating work by using a mobile application instead of existing paper documents). The recorded GPS data will be collected for 60 days and will then be permanently deleted. The provider of the application is TIS GmbH.


ii. Processing of personal data on the basis of legitimate interests

Another lawful basis for processing personal data is the protection of your and/or our rights and interests, or the interests of other persons. This lawful basis includes in particular the following operations:

  • improving and developing our products and services;
  • direct marketing, including offering our products or services or directly related services and products (you may unsubscribe at any time via the link in the message sent);
  • communication with the media (including the use of contact details of media representatives and employees);
  • prevention and detection of criminal activity;
  • establishing, defending and enforcing legal claims and receivables;
  • protection of property and persons, including monitoring the course of transport and monitoring warehouses and depots using CCTV recordings;
  • evaluating and improving our business activities (assessment of service quality, complaints, capacity utilisation, distribution channels, customer portfolio composition, advertising effectiveness, etc.);
  • internal functions necessary for our operations, including at the level of the group of undertakings to which we belong (audit, controlling, IT operations, accounting and tax records, administration, etc.).


In a limited scope, the data will also be processed by our myRaben system as part of a central recipient address database, based on our legitimate interest in consolidating transports addressed to the same recipient.

In order to protect interests, we may also record some of our mutual telephone calls so that we always know exactly what we discussed. We may also subsequently evaluate calls so that we can best meet your requirements, wishes and needs in the future. We may also contact you to verify whether you were satisfied with our services. Where call recording takes place, you will always be informed about the reasons and conditions before the call is made.

You may object to processing based on legitimate interests; we will review the objection and assess whether the processing meets the requirements of the applicable regulations. You can find more information about your rights further in this document.


iii. Processing of personal data on the basis of legal obligations

Legal regulations also in some cases impose on us an obligation to process your personal data. This includes in particular processing for the purpose of:

a. retention and archiving of data pursuant to statutory requirements (accounting and tax regulations, archiving, etc.)

b. fulfilment of other legal obligations (e.g., when processing information in the tax, accounting or other administrative areas)

c. fulfilment of obligations under sector-specific regulations (Act on Road Transport including all implementing regulations, EU regulations and international conventions relating to transport – an overview of regulations can be found on the Ministry of Transport’s website)


iv. Processing of personal data based on the data subject’s consent

In some cases, the processing of personal data requires the consent of the data subject. Details of the purpose and other conditions of processing are stated directly in the relevant consent. Consent to processing may be withdrawn at any time; however, withdrawal of consent does not affect processing carried out before the withdrawal.

For example, in the case of competitions on social networks that involve submitting photographs, you will be asked for consent; alternatively, by uploading photographs in accordance with the competition rules, you will provide us with consent for their use.


v. Processing of data on websites, from plugins and pages on social networks

Our website uses cookies to tailor the content and offers on our pages—for example, to understand which parts of our website people have visited, to help us measure the effectiveness of advertising campaigns and provide us with insights into user interactions and the user base as a whole, so that we can improve our communication and products. When using our website, you will be asked (via a banner with detailed settings and information about individual cookies) to allow the collection and use of cookie data. With your consent, data obtained from cookies and similar technologies may be used for personalisation of communications and offer profiling together with aggregated information relating to customer service, sales and marketing. More information about cookies here.

On the website www.raben-group.com we use Facebook social plugins (“plugins”) owned by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”). The plugins are marked with the Facebook logo and the words “Facebook Social Plug-in”. A list of Facebook plugins and their images is available here: developers.facebook.com/plugins. If you open one of our pages that contains a plugin, your browser automatically connects to Facebook servers. At the same time, personal data are sent to Facebook (currently: IP address, date and time, the viewed website / name of the viewed URL address, and the cookie ID). To the best of our knowledge, the data are processed in the USA. Facebook may combine these data with other information it holds about you. However, as the controller of the website, we have no knowledge of the exact processing of your data by Facebook. Further information about Facebook’s processing of your personal data can be found in Facebook’s Privacy Policy provisions (https://www.facebook.com/about/privacy/).

Together with Facebook, we are joint controllers of the personal data of users who are fans of our pages on https://www.facebook.com/:

• https://facebook.com/rabenlogisticsczech  

Raben Group also has profiles on Instagram, YouTube and LinkedIn (for detailed information see https://www.raben-group.com/privacy-policy).

In view of the above, companies of the Raben Group, as controllers of fan pages, may obtain anonymised statistical data about persons visiting the websites. These data are collected by means of cookies, each of which contains a unique user code (stored by the portal operator on the hard drive of the computer or any other data carrier of persons visiting the fan page). The user code, which may be linked to the data of users registered on the relevant portal, is downloaded and processed when the fan page is opened. These are data that are not linked to specific individuals and which the portal operator may, upon our request, process as:

  • demographic data (including age, gender, marital status and professional status trends),
  • lifestyle and interest information,
  • geographical data that make it possible to determine where to organise special promotional offers or events and how best to target an offer.
     

At the same time, data of persons who have liked a fan page/channel may be processed in a non-anonymised form in the case of:

  • communication with the Raben Group via the relevant portal (this option does not apply to LinkedIn),
  • commenting on posts shared on the fan page/channel,
  • participation in various promotional campaigns and competitions—in this case the processing is carried out on the basis of the user’s explicit consent (this option does not apply to LinkedIn).


Under no circumstances will the data of persons who are fans of the Raben Group pages and of a specific Raben Group company be used for any purpose other than the purpose for which they were provided. Their processing will take place exclusively on the relevant portal and in accordance with the portal’s general terms and conditions of use.

We process the personal data of persons who visit our pages on the basis of the controller’s legitimate interest, or on the basis of consent where we have asked you for it.

We want our fan page to be a place for exchanging opinions and experiences, where users can communicate while observing good manners and mutual respect. Please therefore follow these rules:

a. We do not tolerate hate speech or content of a racist, homophobic, sexist, pornographic, vulgar nature, or content that insults other religions, beliefs or nations.

b. We do not tolerate unlawful conduct or conduct contrary to applicable laws or the rights of third parties, including copyright and intellectual property rights.

c. Pay special attention to information published in comments under posts. The fan page is a public place; therefore, providing data such as a national identification number, identity card number, telephone number or authentication details (login, password) may have negative consequences for a user who publishes this type of information.

We reserve the right to delete or hide posts that violate the above rules.


2. Which personal data do we process?

We primarily process data that we need to offer and provide our services (conclusion of a transport contract and its performance). In simplified terms, this includes all data contained in contracts or similar forms, or data that you have provided to us for this purpose verbally or in another agreed manner. Where necessary given the nature of the service, the processing may also relate to other persons (shipment recipients, transport orderers and senders, employees, drivers, etc.).

Sometimes we will combine your data with other information or create new data derived from or related to those data. This is important mainly for determining rights and obligations arising from the contract, protecting our and/or your interests, or complying with our legal obligations (e.g., improving and developing products, services and business activities, enforcing receivables, or detecting fraud).

Most often, we will process your identification data (company name, name, job position), descriptive and contact data (especially for entering transport orders and delivery), data relating to services or products (e.g., shipment documents including the type or content of the shipment), financial data (e.g., for making payments), data needed to handle your complaints, and other data you provide to us or that we obtain in the course of providing services, including data that we create in connection with our obligations by processing data obtained in this way. If you use one of our web services, we also process data from that service.

We ask you not to provide information constituting special categories of personal data (e.g., data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; data concerning health; genetic data; biometric data; sensitive personal data; or data relating to criminal matters). If, for any reason, you provide such information, this will mean that you give your explicit consent to our collection and use of such data as set out in this document or at the place where the data were disclosed.


CCTV recordings

Our business and work premises may be monitored by CCTV with recording, which we retain for a limited period in order to protect property, the health of persons and our rights (e.g., for documentation of damage to property or goods). The specific premises are always marked with an information sign that contains basic information about the controller and the conditions and duration of processing, and refers to where you can obtain more detailed information.


3. Where do we obtain the personal data from?

We obtain personal data:

1. directly from you when concluding and performing a contract;

2. from our own activities (in particular information relating to services that have been ordered);

3. from other persons where necessary for the performance of contractual obligations, where required by law, or where you have given consent;

4. from publicly available registers, lists, records or websites (e.g., insolvency register, commercial register, trade register, land registry, etc.).


4. To whom may we disclose the personal data?

In addition to us, our employees and persons acting on our behalf, personal data may also be processed by our contracted processors or controllers who participate in providing our services. These include in particular:

  • external partners (carriers) ensuring and carrying out the transport of goods;
  • companies of the Raben Group N.V., in particular to ensure shared internal functions;
  • IT technology providers for the processing of personal data (applications for communication and email management, customer portfolio management and customer relationship management, order management and transport management);
  • suppliers of services necessary for operations (e.g., administrative and office services);
  • providers of specialised services (legal, consulting, financial, audit, HR, etc.);
  • sales representatives or intermediaries.


Raben Group has appointed Raben Management Services sp. z o. o. as its shared services centre managing certain processes relating to services provided to customers, HR and payroll processes, marketing processes (including management of the database of journalists cooperating with Raben Group and corporate social media accounts), IT (including IT systems where personal data of suppliers, drivers, recipients, etc. are collected), security incidents, and also coordinating recruitment processes and risk analyses for all other companies. The company also operates the website www.raben-group.com and therefore coordinates the processing of personal data sent via forms available on this website (e.g., contact form, Raben Group newsletter). Detailed information about shared services can be found in Appendix 1 below.

In order to perform our activities efficiently and to share costs and infrastructure, we may also cooperate with other carriers within the Raben Group and disclose to them the necessary data to perform the ordered services.

Other recipients

If any changes were to occur and we were to transfer our business or other activities as a whole or in part to another person, personal data related to those activities would also be part of such transfer. The same would apply if we were required to make such changes in accordance with applicable laws.

Within legitimate processing, we may also disclose personal data to other persons (e.g., exchange of information for the purpose of fraud prevention, etc.). Where they have a legal basis, other third parties may also gain access to personal data (e.g., the police and other public authorities).

Confidentiality

All persons who cooperate with us and who come into contact with personal data in the performance of their work or contractual obligations are bound by confidentiality and comply with adequate standards for securing your data.


5. When may we transfer personal data abroad?

Your personal data may be transferred for processing within the EU and the European Economic Area (e.g., to companies of the Raben Group N.V., IT technology providers, or other processors and controllers). If it is necessary to transfer personal data to countries outside the EU/EEA (e.g., in the case of transport outside the EU), we will always do so only after ensuring an adequate level of protection and documenting safeguards ensuring that the data will be handled in accordance with applicable laws. These safeguards include, in particular, the standard contractual clauses approved by the European Commission. Upon your request, we will provide you with specific information on transfers, including the content of these standard contractual clauses. Contact details for submitting requests are provided in the header of this notice.

A specific case arises when personal data are transferred to a third country in connection with the provision of international transport services for goods outside the EEA by a foreign carrier from countries outside the EEA. The transfer of data to a third country will take place pursuant to Article 49(1)(b) or (c) of the GDPR, i.e., where the transfer is necessary for the performance of a contract between the data subject and the controller or for the implementation of pre-contractual measures taken at the data subject’s request, or where the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the data subject between the controller and another natural or legal person.


6. How long do we keep your data?

The retention and archiving period for personal data depends on several factors, which apply depending on the specific situation in which the personal data are processed. Most often, personal data are processed for the duration and performance of contractual or also non-contractual obligations (for simplicity hereinafter “contract”). After the contract ends, personal data continue to be processed for the purpose of protecting our or your rights and interests (or, as the case may be, the interests of third parties), for the period strictly necessary to safeguard or exercise them. This period is primarily determined by (objective) limitation periods set by law (Civil Code) or by the contract. The periods may differ depending on the type of obligation or right to which the data relate. For certain documents, we are obliged to retain the data contained therein for the periods laid down by generally binding legal regulations (in particular in the areas of road transport, accounting, taxes, labour law, or archiving under special legislation).

In the case of responses to your inquiries or other similar communications, we retain such records for two months from the end of the communication with you. In relation to marketing consents collected via the contact form on our website, such marketing consents may be used during the handling of your inquiry. After this phase, any further marketing communication is carried out only if a contact record containing your personal data has been created in our system. If no contact record is created, the data are used exclusively for handling the inquiry and are subsequently deleted or anonymised in accordance with the retention period stated for inquiries and other communications.

Where processing is based on your consent, the processing is carried out until the consent is withdrawn, unless the consent specifies otherwise. You may withdraw your consent at any time and thereby end the processing.


7. What are your rights?

In relation to the processing of your personal data, you may exercise the following rights:
 

Right to be informedYou have the right to receive information before processing and during processing, upon your request. Upon request, we will inform you whether we process your personal data and, if so, also (where you request it) information on the purposes, categories of data, recipients (or categories of recipients), retention period (or criteria), your rights including the right to lodge a complaint with a supervisory authority, the sources of the data (if they do not originate from you), the existence of automated individual decision-making, and transfers to a third country or an international organisation (including suitable safeguards).
Right of accessThe controller should process accurate data; if you discover that data are inaccurate, you have the right to have them rectified.
Right to rectificationThe controller should process accurate data; if you discover that data are inaccurate, you have the right to have them rectified.
Right to erasure
(“right to be forgotten”)
You have the right to have your data erased, but only where no other legally recognised ground for processing exists that the controller may rely on (including the protection of its legitimate interests and rights).
Right to data portabilityYou have the right to receive the processed data, which are processed on the basis of consent or for the conclusion or performance of a contract, and which you have provided yourself or which directly result from your activity, in a machine-readable format. This applies only to data processed by automated means.
Right to objectThis applies to cases of processing carried out for reasons of public interest pursued by the controller, or for the controller’s own legitimate interests, including direct marketing. You have the right to object to such processing and the controller is obliged to assess such processing for compliance with all requirements under applicable regulations. In the case of direct marketing, such processing will always be stopped once an objection has been raised.
Right to withdraw consentIn the case of processing based on your consent, you may withdraw your consent at any time by sending a request to the email address  gdpr.cz@raben-group.com.
Right to restriction of processing

You have the right to restriction of the processing of your data if:

- you contest the accuracy of the data, for the period enabling the controller to verify the accuracy of the data;

- the data are no longer necessary for the purposes of the processing, but you require the processing for the establishment, exercise or defence of legal claims;

- you have objected to the processing, pending the verification whether the controller’s legitimate grounds override your legitimate interests;

- the processing of the data is unlawful and you request restriction of processing instead of erasure of the data.

Right to lodge a complaint with a supervisory authority / a courtYou may contact the supervisory authority (Office for Personal Data Protection – www.uoou.cz) or a court.

We do not carry out any automated decision-making.  

 

How can you exercise your rights?
 

We handle your requests relating to the processing of personal data without undue delay and at the latest within one month of receipt of such request. This period may, where necessary and taking into account the complexity and number of requests, be extended by a further two months. If this occurs, we will inform you of such extension within one month of receiving the request, together with the reasons for the delay.

Contact point for requests and questions relating to the processing of personal data: gdpr.cz@raben-group.com



8. What if something changes?

We will update this notice regularly and it will always be available on our website. If there is a material change in the processing of personal data, we will inform you directly.


Version effective from 4.3.2026

 

Appendix 1

List of joint controllers

The parties to the joint controllership arrangement between the companies of the Raben Group are the following companies (hereinafter the “joint controllers”):

  • Raben Management Services spółka z ograniczoną odpowiedzialnością, registered office in Robakowo (62-023), ul. Zbożowa 1,
  • Raben Trucking & Rental GmbH, registered office in Mülheim-Kärlich (56218), Germany, Urmitzer Str. 9,
  • Raben ECP GmbH, registered office in Mannheim (68219), Germany, Holländerstr. 11,
  • Raben Trans European Germany GmbH, registered office in Mannheim (68219), Germany, Holländerstr. 11,
  • Raben Germany Immobilien GmbH, registered office in Mannheim (68219), Germany, Holländerstr. 11,
  • Raben Trans European Immobilien GmbH, registered office in Mannheim (68219), Germany, Holländerstr. 11,
  • Raben 4PL Solutions GmbH, registered office in Mannheim (68219), Germany, Holländerstr. 11,
  • Raben Sea & Air GmbH, registered office in Hamburg (22113), Germany, Bredowstraße 30,
  • Raben Real Estate Poland spółka z ograniczoną odpowiedzialnością, registered office in Robakowo (62-023), ul. Zbożowa 1,
  • Raben Transport spółka z ograniczoną odpowiedzialnością, registered office in Gądki (62-023), Poland, ul.  Poznańska 71,
  • Raben East spółka z ograniczoną odpowiedzialnością, registered office in Robakowo (62-023), ul. Zbożowa 1,
  • Raben Logistics Polska spółka z ograniczoną odpowiedzialnością, registered office in Robakowo (62-023), ul. Zbożowa 1,
  • Fresh Logistics Polska spółka z ograniczoną odpowiedzialnością, registered office in Robakowo (62-023), ul. Zbożowa 1,
  • Raben Business Services spółka z ograniczoną odpowiedzialnością, registered office in Robakowo (62-023), ul. Zbożowa 1,
  • Raben Sea & Air SE, registered office in Robakowo (62-023), ul. Zbożowa 1,
  • Raben Group N.V., registered office in Oss (5342LW), the Netherlands, Vorstengrafdonk 81,
  • Raben Netherlands B.V., registered office in Oss (5342LW), the Netherlands, Vorstengrafdonk 81,
  • Ascari Investments B.V., registered office in Oss (5342LW), the Netherlands, Vorstengrafdonk 81,
  • Raben Real Estate Holding S.E., registered office in Oss (5342LW), the Netherlands, Vorstengrafdonk 81,
  • Raben Real Estate Netherlands B.V., registered office in Oss (5342LW), the Netherlands, Vorstengrafdonk 81,
  • Raben Trucking Netherlands B.V., registered office in Etten-Leur (4878AH), the Netherlands, Parallelweg 3,
  • G.J. Groep B.V., registered office in Etten-Leur (4878AH), the Netherlands, Parallelweg 3,
  • Raben Logistics Czech s.r.o., registered office in Nupaky (251 01), Czech Republic, Komerční 535,
  • Raben Transport s.r.o., registered office in Kostelec (349 01), Czech Republic, Ostrov u Stříbra 64,
  • Raben Logistics Slovakia s.r.o., registered office in Senec (903 01), Slovakia, Diaľničná cesta 28,
  • Raben Sittam S.r.l., registered office in Cornaredo (20007), Italy, Via Monzoro 100,
  • Raben Trans European Hungary Kft., registered office in Dunaharaszti (2330), Hungary, Jedlik Ányos út 31,
  • Raben Real Estate Hungary Kft., registered office in Dunaharaszti (2330), Hungary, Jedlik Ányos út 31,
  • Raben Logistics Romania S.l.r., registered office in Dragomiresti - Deal (077096), Romania, Strada Padurii no. 26, CTPark BUCH 14,
  • Raben Logistics Bulgaria EOOD, registered office in Sofia, Bulgaria, Tsar Kaloyan Street 8, 2nd floor,
  • Raben Lietuva UAB, registered office in Vilnius (LT-02120), Lithuania, Liepkalnio 85B,
  • Raben Real Estate Lithuania UAB, registered office in Vilnius (LT-02120), Lithuania, Liepkalnio 85B,
  • Raben Latvia SIA, registered office in Dreiliņi, Stopiņu pagasts, Ropažu novads (LV-2130), Latvia, Garā iela 2,
  • Raben Eesti OU, registered office in Harju maakond, Rae vald, Peetri alevik (75312), Estonia, Reti tee 4,
  • Raben Intertrans AE, registered office in Athens (18546), Greece, Agiou Dimitriou 41,
  • Raben Real Estate Greece MIKE, registered office in Athens (18546), Greece, Agiou Dimitriou 41,
  • Raben BEXity GmbH, registered office in Vienna (1110), Austria, Warneckestraße 7.

 

List of processing purposes covered by joint controllership

The companies of the Raben Group jointly control personal data in the following processes in pursuit of the jointly agreed objectives listed below:

Process

 

Purpose

 

Recruitment – selection of job applicants for key positions (decision-making process)Conducting recruitment
Recruitment – hiring/selection of job applicants for key positions – participation of Raben Management Services sp. z o.o. in decision-makingConducting recruitment
Employment – access to employee remuneration data of Raben Group companiesHuman resources management according to group standards
Archiving – setting archiving rules (scope, retention, access rights)Ensuring the security of archived data and compliance of the archiving process with regulations.
Customer service (returns/complaints) – support in handling complaints and decision-making in complaint proceedingsCarrying out activities necessary to perform and complete the insurance claims handling process.
Customer service – Track & Trace serviceTaking necessary measures to ensure proper execution of deliveries (shipment status information).
Customer services – contact database managementManagement of information on customer consents (maintaining proper communication with customers).
Customer services – service quality surveysSurveying satisfaction with the services provided
Customer service – inquiriesTaking the steps necessary to handle requests
Customer service – operational website forms (for customer service and sales of services)Communication with customers and prospective customers
Sales of servicesCarrying out activities aimed at the sale of services provided by Raben Group companies.
Customer serviceProviding services to customers in accordance with the contract
Document flow – transfer of data and financial documents (with regard to certain performance thresholds arising from Corporate Governance)Maintaining the integrity of the accounting system and fulfilling legal obligations.
Cybersecurity – security testingEnsuring IT security
Cybersecurity – management of cybersecurity incidentsIdentification and resolution of security incidents
Helpdesk – in connection with software errorsResolving issues with the software in use
Physical security – theft preventionEnsuring the security of goods
Online marketing – social media pages (where this concerns a separate social media profile)Building the Raben Group image and promoting the services provided.
Online marketing – organising competitions on social networksBuilding the Raben Group image and promoting the services provided.
Online marketing – newsletter (subscription and content preparation)Building the Raben Group image and promoting the services provided.
Online marketing – personalisation of offers and profilingBuilding the Raben Group image and promoting the services provided.
Occupational health and safety – activities related to security incidentsPrevention and management of incidents in the area of occupational health and safety
Occupational health and safety – reporting safety events within the groupPrevention and management of incidents in the area of occupational health and safety
Legal servicesSupport in contract review, participation in negotiations, support in contract execution, support in complaint proceedings, and other activities related to legal support for Raben Group companies.
Cooperation with banksCarrying out transactions and other matters related to interactions with banks with which Raben Group companies cooperate.
Activities of the “managing company”Other matters related to directing the activities of Raben Group companies

 

Key elements of the joint controllership arrangement

In accordance with Article 26(2) GDPR, we provide below the basic content of the arrangements between the joint controllers concluded under the joint controllership agreement:

The joint controller that has a decisive influence on the selection and provision of technical means for the processing of personal data within the scope set out above, including in particular hardware and software, is Raben Management Services spółka z ograniczoną odpowiedzialnością (hereinafter “RMS”).

  • The engagement of any processor in the processes covered by joint controllership always requires the consent of RMS, which is also authorised to enter into data processing agreements on behalf of all joint controllers;
  • Each of the joint controllers is responsible for fulfilling information obligations under the GDPR. The content of the information to be provided is the result of joint arrangements between the joint controllers. The joint controllers are required to take into account RMS instructions on the content of the information to be provided;
  • Each joint controller maintains its own record of processing activities and, where applicable, a record of categories of processing activities;
  • RMS is the joint controller obliged to carry out the initial data protection risk analysis and, where applicable, the data protection impact assessment (DPIA). The conclusions of the analyses are prepared jointly by the joint controllers;
  • In the case of international transfers of personal data, in particular to countries outside the EEA, the joint controllers are obliged to apply additional safeguards in accordance with the GDPR and to set rules for informing natural persons about such transfers and their rights;
  • Each joint controller is responsible for the processing of personal data in accordance with the GDPR, including in particular for enabling and handling the exercise of data subject rights;
  • Data subjects may request the exercise of their GDPR rights from any of the joint controllers at their discretion and choice; however, the primary contact is the controller that is in a direct relationship with the data subject;
  • Each joint controller is required to maintain a register of requests, kept in a manner ensuring the integrity and confidentiality of the data contained therein;
  • Data subjects have the right to lodge a complaint in connection with the processing with any supervisory authority of their choice that has territorial jurisdiction over any of the joint controllers;
  • The joint controllers cooperate closely in handling data subject requests;
  • In the event of a personal data breach within the scope of joint controllership, each joint controller is obliged to inform the other joint controllers of a suspected breach without undue delay and in any event no later than 24 hours after becoming aware of the breach;
  • The joint controllers are obliged to participate in investigating the identified breach. The joint controller that identified the breach is obliged to carry out a preliminary assessment of the risk posed by the breach to the rights and freedoms of the affected natural person and to communicate the results to the other joint controllers;
  • Based on the results of the risk assessment carried out, the joint controllers will jointly decide whether to notify the personal data breach to the competent supervisory authority and to the data subjects, and they will designate the joint controller responsible for fulfilling the above information obligations.