THE GDPR

Information about personal data processing by "ERBUD – COMMON CHALLENGES" Foundation named after Eryk Grzeszczak

1. Who is the Controller of your personal data?

The Controller of the personal data (hereinafter "Data") processed by us in connection with the conduct of foundation activities is the "ERBUD – COMMON CHALLENGES" Foundation named after Eryk Grzeszczak with its registered office in Warsaw at ul. Franciszka Klimczaka 1 (02-797), hereinafter referred to as the Controller or the Foundation.

In connection with the fact that the Foundation is affiliated with the ERBUD Capital Group, in certain cases, the Data may also be transferred to other companies of the ERBUD Group. The list of all companies that are members of the ERBUD Group is attached here.

2. What is Data?

Data means any information about an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the natural person.

3. How do we process Data?

Data are processed in accordance with current legislation including the General Data Protection Regulation (GDPR)1 .

he Foundation takes special care to protect the interests of Data Subjects, and in particular ensures that the Data collected is:

  • processed lawfully, fairly and in a manner transparent to the Data Subject;
  • collected for specified, explicit and legitimate purposes and not further processed in a way incompatible with those purposes;
  • adequate, relevant and limited to what is necessary for the purposes for which they are processed;
  • correct and updated as necessary;
  • kept in a form, which allows for identification of the Data Subject for not longer than is necessary for the purposes for which the Data is processed;
  • processed in a manner that ensures adequate security of the Data, including protection against unauthorized or unlawful processing and accidental loss, destruction or damage, by means of appropriate technical or organizational measures.

4. When do we process Data?

We process data under numerous circumstances. This may be the case when you have provided us with your Data personally through various communication channels (e.g. by submitting your application, sending us a request by e-mail or by phone), as part of our cooperation during the signing or performance of a contract, but also when we have obtained your Data from other sources (e.g. from a childcare centre with which we have cooperated in the framework of our statutory activity) or in the framework of other foundation activity. We describe the Data processing methods below.

5. Data processing in connection with business relationships and contact.

a. How do we process Data in connection with business relationships and contact?

As the Data Controller we process Data of our business partners, their employees / associates. Data of other persons provided to us in the framework of contract performance, as well as other persons cooperating with the Foundation for the purpose of its statutory activities and persons getting in touch with us by phone or via e-mail.

In relation to the business relationship and contact, we may process the following Data: Identification Data, Contact Data, Job and Professional Privilege Data, and other Data provided to us in connection with the collaboration or contact.

We collect the above Data directly from Data Subjects, as well as from others, such as their employers/contractors..

b. What is the purpose and basis for processing the Data in connection with the business relationship and contact?

In relation to the business relationship and contact, we process Data for the following purposes:

  • to establish co-operation;
  • to enter into and to perform contract;
  • to settle the contracts;
  • to respond to any inquiries or requests made and to maintain further correspondence/contact to this extent;
  • for marketing purposes and to contact about other Foundation information and services;
  • to defend against potential claims, as well as for the possible referral of claims.

The Foundation's grounds for Data processing is:

  • a necessity to perform a contract or to take steps prior to entering into a contract upon the request of the Data Subject;
  • execution of legal duties imposed on the Data Controller ;
  • The legitimate interest of the Administrator in the form of marketing the Administrator's or a third party's products and services, contact, including correspondence, and defence against potential claims.

Data delivery is voluntary, however, it may be necessary in order to conclude or perform a contract or in order to reply to an inquiry or for correspondence purposes.

c. How long are you going to process Data in connection with the business relationships and contact?

Data collected for the purpose of entering into and performing a contract will be processed during the life of the contract and thereafter until the statute of limitation of possible claims has expired.

The data of those who have contacted the Foundation will be processed for the period necessary for the response and possible correspondence, and then until the expiration of the limitation period for any possible claims.

d. Who is the recipient of the Data in connection with the business relationship and contact?

Data processed by us in connection with business relations and contact may be transferred to other companies of the ERBUD Group, our business partners and service providers, and our other contractors supporting us in the organization of work, IT services and marketing.

6. Processing of recruitment-related Data.

a. What recruitment-related Data do we process?

As the Data Controller, we process Applicants' Data provided to us through all available recruitment channels, including, in particular, processing any Data provided to us as part of an application and collected as part of the recruitment process.

We may process the following recruitment-related Data (processing of some Data may be subject to your consent): Identification Data, Contact details, Educational Background Data, Skills and previous Employment Data, Qualifications Data and other Data provided to us during the recruitment process.

b. What is the purpose and grounds for processing recruitment-related Data?

In connection with the recruitment process we process Data for the following purposes:

  • to examine the application and execute the recruitment process, and in the case of consent, also for the purposes of future recruitment or recruitment within the ERBUD Group;
  • to defend against potential claims, as well as for the possible referral of claims.

The grounds for Data processing are as follows:

  • fulfilment of the obligations arising from legal regulations (defining the scope of data collected from a person applying for employment - in particular the Labour Code and executive acts);
  • taking actions before entering into a contract at the request of the data subject;
  • consent to data processing (in case of data broader than specified by law);
  • legitimate interest of the controller (defence against possible claims).

Data disclosure is voluntary, however it is necessary to conduct the recruitment process and establish possible further cooperation.

c. How long are you going to process recruitment-related Data?

As a rule, the data will be processed for the purposes specified above for the duration of the recruitment process or, depending on the voluntarily given consent regarding participation in future recruitments, no longer than 2 years.

d. Who is the recipient of the recruitment-related Data?

The recruitment-related Data that we process may be transferred to other ERBUD Group member companies, to legal advisers and entities supporting us in the recruitment process and IT service providers.

7. Data processing in connection with the organization of Support Programmes.

a. What Data do we process in connection with the organization of the Programmes?

Acting in the capacity of Data Controller we process:

  • Data of persons participating in the Foundation's permanent programmes (TOGETHER Program and Success Recipe program) and ad hoc programmes;
  • Data of persons involved / contacted in cooperation with educational facilities;
  • Data of mentors.

In connection with the organization of the Foundation's permanent and ad hoc programmes, we may process the following Data (processing of some Data may be subject to your consent): Identification Data, Contact details, Data on granting the additional assistance, including health data, data relating to education under the TOGETHER Program, Data relating to psychological assistance provided under the Prescription for Success Program, including health data, Image, other Data provided in connection with participation in the Foundation's permanent and ad hoc programmes.


b. What is the purpose and basis for processing the Data related to the arrangement of the Programmes?

In connection with the arrangement of the Foundation's permanent and ad hoc programmes, we process Data for the following purposes:

  • to implement of activities within the framework of permanent and ad hoc programmes (including training, workshops, meetings, therapy sessions)
  • to conduct marketing activities for the Foundation's on-going and ad hoc programmes, including sending event invitations and newsletters;
  • to establish cooperation;
  • to enable the partner organization to participate in the program and its trainings, workshops and meetings;
  • to provide substantive support to the program and its beneficiaries, to promote and advertise the program, etc.
  • to settle contracts;
  • to respond to all inquiries and to maintain further correspondence / contact to this extent;
  • to fulfil legal obligations (e.g. settlement of accounts / taxes)
  • to defend against potential claims, as well as for the possible referral of claims.

The Foundation's grounds for Data processing are as follows:

  • consent to Data processing;
  • a necessity to perform a contract or to take steps prior to entering into a contract upon the request of the Data Subject;
  • execution of legal duties imposed on the Data Controller;
  • Legitimate business of the Data Controller, including implementation of regular and ad hoc programmes, marketing Data Controller's or third party's products and services, contact, correspondence and defence against potential claims.

c. How long will the Data be processed in connection with the organisation of the Programmes?

Data collected for the purposes of organising and carrying out activities as part of permanent and ad hoc programmes or events connected with statutory activities will be processed until the end of a given programme edition, the end of a given event or the performance of a concluded agreement, and then until the statute of limitations for claims resulting from participation in the programme and/or concluded contract.

The data of persons who have got in touch with the Foundation under its permanent and ad hoc programmes will be processed for the time necessary to provide an answer and, if applicable, to conduct correspondence, and then until the expiry of the statute of limitations for any claims.

d. Who is the recipient of the Data related to the Programmes’ organisation?

Data processed by us in connection with the organisation of the Foundation's permanent and ad hoc programmes may be transferred to other ERBUD Group member companies, accounting advisers, legal advisers, entities providing IT support and operational services as well as payment tools and systems, and entities/service providers as part of cooperation related to the implementation of a given programme and IT service providers.

8. Processing of the Mentors' Data and other persons supporting us in the implementation of the Programmes and statutory activities.

a. What Data we process in connection with the cooperation established with mentors?

As a Data Controller, we process the Data of mentors involved in the foundation activities of persons involved in the organisation of mentoring programmes.

In connection with the organisation of mentoring programmes, we may process the following Data (the processing of some Data may depend on your consent): Identification Data, Contact details, Business Data in the case of mentors (including e.g. education, work experience, company name, business profile), Image.

b. What is the purpose and grounds for the processing of the Data related to the working relationships established with the mentors?

In connection with the working relationships established with the mentors, we process Data for the following purposes:

  • to organize mentoring programmes, including training sessions, workshops and meetings;
  • to implement the activities within the mentoring programme (including in particular coordination of cooperation with start-ups);
  • to run marketing activities, including invitations to events and to disseminate the newsletters..

The Foundation's grounds for Data processing are as follows:

  • pre-contractual action upon the request of the data subject;
  • necessity to perform a contract;
  • realization of legally justified interests (marketing purposes, defence against possible claims, realization of statutory tasks of the Foundation and the programme);
  • consent to data processing.

c. How long the Data related to the working relationships established with the mentors will be processed?

Data collected for the purposes of organising mentoring programmes will be processed until the end of a given edition of a mentoring programme or the performance of a concluded agreement, and then until the statute of limitations for claims arising from participation in the programme and/or a concluded agreement, the time of lodging an objection, withdrawal of consent - whichever of these periods is longer.

d. Who is the recipient of the Data in connection with the cooperation established with the mentors?

Data processed by us in relation to cooperation established with mentors may be transferred to other companies from the ERBUD Group, accounting advisors, legal advisors, entities participating in the organisation of events, in particular hotels, restaurants, event agencies, transport companies and entities providing support and operation of IT and payment tools and systems.

9. Processing of data of donors and participants of events organised by the Foundation.

a. What Data of donors and participants of events organised by the Foundation do we process?

As a Data Controller we may process the Data of donors, participants in charity auctions and balls and those who transfer money to the Foundation's account, persons transferring 1% to the Foundation.

In view of the above, we process the following Data:

  • Identification data,
  • Phone and address details:
  • Bank account number;
  • Data concerning the amount of 1% (in case the donor indicates the intention to transfer this data to the Foundation as part of the tax return);
  • Image.

b. What is the purpose and basis of the processing of the Data of donors and participants in events organised by the Foundation?

In connection with Foundation activities, we process Data for the following purposes:

  • the implementation of foundation activities;
  • organisation of charity balls and auctions.

The Foundation's grounds for Data processing are as follows:

  • fulfilment of legitimate interests;
  • fulfilling a legal obligation incumbent on the Controller (to issue and keep invoices and accounting documents);
  • consent to the processing of personal data.

c. How long is the Foundation going to process the Data of donors and participants in events organised by the Foundation?

The data of donors and participants in events organised by the Foundation, depending on the type of data, will be processed for the period resulting from the applicable laws, and then until the statute of limitations, the time of lodging an objection, withdrawal of consent - whichever of these periods is longer.

d. Who is the recipient of the Data of donors and participants in events organised by the Foundation?

The data of donors and participants in events organised by the Foundation may be transferred to other companies from the ERBUD Group, accounting advisors, legal advisors, entities participating in the organisation of events, in particular hotels, restaurants, event agencies, and entities providing support and operation of IT and payment tools and systems.

10. Processing of data in connection with the marketing activities of the Foundation and ERBUD Group.

a. What Data we process in connection with marketing activities?

As an Administrator we process Data of persons engaged in the marketing activity of the Foundation consisting in creating and using videos and photos for promotional activities.

In connection with conducting the above described marketing activities, we may process the following Data (processing of some Data may depend on your consent): Identification Data, Contact Data, Image.

b. What is the purpose and basis for processing the Data in connection with marketing activities?

In connection with our marketing activities, we process Data for the following purposes:

  • building the image of the Foundation and promoting its activities, in particular for the purpose of creating promotional videos / photos;
  • promotion and building the image of the ERBUD Group;
  • mailing information about the Foundation's activities in paper form.

The Foundation's grounds for Data processing are as follows:

  • consent to Data processing;
  • legally justified interest of the Administrator in the form of marketing and image building of the Foundation and the promotion and building the image of the ERBUD Group

c. How long the Data will be processed in connection with marketing activities?

Data collected for the purpose of marketing, in particular for the purpose of creating promotional videos/photos, will be processed until you raise an objection, withdraw your consent, for the period required by law or the statute of limitations for potential claims - whichever is longer.

d. Who is the recipient of Data related to the marketing activities?

Data processed by us in relation to the marketing activities may be transferred to other companies from the ERBUD Group, accounting advisers, legal advisers, entities providing support and operation of IT tools and systems, entities providing support and operation of IT tools and systems, postal operators and entities / service providers as part of cooperation related to the implementation of marketing activities and entities providing IT services to us.

11. Is your Data going to be transferred to the non-European Economic Area (EEA)?

As a general rule, your Data will not be transferred by the Controller to countries outside the European Economic Area ("EEA"). Exceptionally, we may transfer your Data to our partners who process it in the non-EEA, but only to the extent necessary in connection with the delivery of services by those partners to us or another business relationship between us. We will transfer your Personal Data to countries that have been found by the European Commission to have an adequate level of protection, or failing that, the security of your Data is ensured by the safeguards we apply, including but not limited to standard contractual clauses approved by the European Commission.

You have the right to obtain a copy of the safeguards for your Data transferred to countries outside the EEA by contacting us at the following email address: fundacja@fundacjaerbud.pl

12. Do we process the Data of minors?

Within the scope of our statutory / marketing activities, we may also process the Data of minors. In such a case we strive to ensure that further processing of the Data of such persons is carried out in compliance with applicable laws and with heightened security principles, e.g. in the case of processing of the Data on the basis of a consent of a legal guardian of a minor.

The Foundation shall not process the Data of minors without obtaining prior consent to process the Data expressed on their behalf by their legal guardian

13. What rights do you have?

In any case, you have the right to:

  • access to the Data (including, for example, to receive information about which Data is processed);
  • request to rectify and restrict Data processing (e.g. if Data is incorrect);
  • delete Data (e.g. if they have been unlawfully processed);
  • Data which you have provided to the Data Controller and which is processed by automatically and the processing is based on consent or on a contract, e.g. to another Data Controller;
  • object to the processing of the Data if required for the purposes arising from the legitimate interests pursued by the Data Controller or by the third party, including in particular to the processing for marketing purposes;
  • odge a complaint to the President of the Data Protection Authority.

If the processing of Data is based on consent, you have the right to withdraw it at any time without affecting the legality of processing carried out on the basis of consent before its withdrawal.

14. Automated decision-making process, including profiling

The Data Controller shall not process the Data by automated decision-making, including profiling, referred to in Article 22(1) and (4) of the RODO which produces legal effects on the Data Subject.

15. Contact:

You may contact the Foundation at: fundacja@fundacjaerbud.pl or by the phone: +48 22 161 53 07.


1 The 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 (General Data Protection Regulation - GDPR).