TERMS & CONDITIONS
Terms of Use.
TWN4 HCE ARCUS (the “App”) allows you to present certain data about your mobile device (IMEI number and/or device ID number and/or device name (the “Identification Data”)) to other devices and or systems for the purposes of identification. Such other system may collect various personal information about you and such data collection is out of scope of the App and this Terms of Use and our Privacy Policy. Please acquaint yourself with the terms of use and privacy policy of such other system or device before you decide to present your Identification Data to such system or device via the App. The App is provided to you by Arcus S.A. with its registered seat in Warsaw (01-217), address 5/7 Kolejowa street, entered into the register of entrepreneurs the National Court Register maintained by the District Court for the Capital City of Warsaw, XII Commercial Division of the National Court Register under the number 0000271167 having Tax Identification Number (NIP) 526-03-08-803, with share capital (wholly paid) PLN 732 000, telephone number +48 22 536 08 00, +48 22 536 09 00 e-mail: arcus@arcus.pl , www.arcus.pl (hereinafter referred to as “Arcus” or “we”, “us” or “our”). The App was made accessible to allow cooperation with other systems, mainly operated by Arcus’ clients, however it is also possible to use the App to identify to other independent systems. The App works fully automatically and presents Identification Data to other system via NFC (near field communication). If such system recognizes the Identification Data, it grants access to the system. If not the access is denied and the App may or may not inform about such deny. If you would like to cancel the service provided by the App, please simply remove the App from your device. Please also acquaint yourself with Privacy Policy describing how your data are used by the App. Should you have any questions or comments regarding the App please contact us by phone or by e-mail using details indicated above. Your personal data may be then used to deal with your enquiries and requests, but such data are not processed in the App and will be deleted after reasonable time after your enquiry is resolved.
PRIVACY POLICY
We are committed to protecting and respecting your privacy. This Privacy Policy explains the types of personal information we collect, how we use that information, who we share it with, and how we protect that information. This Privacy Policy supplements our Terms of Use, and all terms used in this Privacy Policy with an initial capital letter have the meaning ascribed to them in the Terms of Use. Please read the following carefully to understand our views and practices regarding your personal information, and how we will treat it. If you do not want us to collect, process and use your personal data as described in this Privacy Policy, you should not use our App.
Who we are
For the purposes of applicable data protection laws (including the EU Data Protection Directive 95/46 and implementing local laws, and any legislation that replaces or supersedes such laws), Arcus is a data processor on behalf of Arcus’s clients being data controllers of your Personal data (hereinafter referred to as the “Data Controllers”).
Information covered by this Privacy Policy
This Privacy Policy covers all personal information collected and used by Arcus through or in connection with the App usage. “Personal data” or “personal information” means information that (either in isolation or in combination with other information held by us and/or the Data Controllers) enables you to be identified as an individual or recognised directly or indirectly.\
Information we collect about you
The App collects only Identification Data such as IMEI number and/or device ID number and/or device name. The App does not host or record other data about Identification Data presentation in particular the App does not archive any statistics how often or how long the App was used.
Information the Data Processor collect about you
The App presents the Identification Data to the system you requested by connecting the App with other device via NFC. Such other system may collect various personal information about you and such data collection is out of scope of the App and this Privacy Policy. Please acquaint yourself with the terms of use and privacy policy of such other system before you decide to present your Identification Data to such system via the App.
How do we process your personal information?
We present the Identification Data only to the system you requested by connecting the App with other device via NFC.
What is the legal basis for us processing your information in this way?
Processing your Identification Data in this way is necessary to facilitate the specific use of the App. Using your Identification Data in this way is necessary for us to perform our contractual obligations towards Data Processor (our client). It may sometimes be necessary for us to process your information to comply with our legal obligations.
Your rights
You have the legal right to request details of the personal information that we hold about you, to ask us to stop processing your information where you have previously consented to us doing so, to have it corrected or deleted.
Your right to access the information we hold about you
You can request access to the information we hold about you by contacting us using the contact details set out below. Our file of your information will usually be made available to you within 30 days, although occasionally we may not be able to give you access to the personal information we hold about you (for example, we may not be able to give you access if it would unreasonably
affect someone else’s privacy or if giving you access poses a serious threat to someone’s life, health or safety). Please note that we may apply an administrative charge for providing access to your information in certain circumstances. Any such charge will be reasonable and we will advise you of the charge and obtain your consent before providing you with access to your personal information. Please note that if you request a copy of your data using electronic means (such as email), then we will provide a copy of your information in electronic form unless you ask us to do otherwise.
Your right to have your information corrected or deleted
If you would like us to correct or delete your information, please email your request to arcus@arcus.pl and we will action it as soon as possible. Please also acknowledge that if you delete the App we will automatically and immediately delete all your information.
Your right to object to us processing your personal information
You have the right to ask us to stop processing your personal information, even where that processing is necessary for our legitimate interests (for example, where the processing is necessary for the commercial objectives we pursue in the course of our business).
Making a complaint
You have the right to lodge a complaint with a local data protection authority in the European Economic Area (EEA) if you believe that we have not complied with applicable data protection laws. The local data protection authority will differ depending on the country you are in. Please see the Annex to this Privacy Policy for a list of local data protection authorities in the EEA countries in which we operate.
Right to withdraw your consent
You have the right to withdraw your consent at any time. Such a withdrawal does not affect the lawfulness of the processing prior to the withdrawal.
Contacting us
If you want to exercise any of the rights detailed above, have any questions or concerns about how we treat your personal information, wish to ask us to stop processing your personal information, or would like to request a copy of the personal information we hold about you, please contact us at : arcus@arcus.pl or by writing to us at:
Arcus S.A. 5/7 Kolejowa street 01-217 Warsaw, Poland
Please include your reply address when you write to us.
How long do we keep your personal information?
Your personal information is stored by us for the time you use the App. After the App is deleted we do not store any your information.
Changes to this Privacy Policy
We may update this Privacy Policy from time to time in response to changing legal, regulatory or operational requirements. We will notify you of any such changes (including when they will take effect). If required, we will request your consent to any material changes in how we process your personal data. If you do not consent, you may no longer be able to use the App.
Annex
List of data protection authorities (EEA countries)
You have the right to lodge a complaint with local data protection authorities in the EEA if you believe we have not complied with applicable data protection laws. The local authority differs depending on the country. Please see below for details of the local data protection authorities in the EEA countries in which we operate.
Czech Republic
The Office for Personal Data Protection Urad pro ochranu osobnich udaju
Pplk. Sochora 27 170 00 Prague 7 Tel. +420 234 665 111 Fax +420 234 665 444 e-mail: posta@uoou.cz Website: http://www.uoou.cz/
Poland The Bureau of the Inspector General for the Protection of Personal Data – GIODO
ul. Stawki 2 00-193 Warsaw Tel. +48 22 53 10 440 Fax +48 22 53 10 441 e-mail: kancelaria@giodo.gov.pl; desiwm@giodo.gov.pl Website: http://www.giodo.gov.pl/