Privacy policy Garden of Words Group

This Privacy Policy aims to inform you about the principles governing the processing of personal data by entities belonging to the Garden of Words Group, in particular who acts as the data controller, for what purposes personal data are processed, and what rights are granted to individuals whose data are processed.

1. Personal Data Controllers

Garden of Words Group is a group of entities operating in the fields of communication, strategy, public relations and advertising. Each company within the group acts as a separate data controller within the meaning of Article 4(7) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of personal data (GDPR).

The personal data controllers are:

1. Garden of Words sp. z o.o. registered office in Warsaw, ul. Chmielna 21/19, 00-021 Warsaw, Poland KRS 0000973765, NIP 7011089585, REGON 522114751 data controller in the scope of PR activities, CSR projects, ESG communication, and communication campaigns, including campaigns addressed to women.

2. Fresh Think sp. z o.o. registered office in Warsaw, ul. Chmielna 21/19, 00-021 Warsaw, Poland KRS 0000972540, NIP 7011088700, REGON 522067000 data controller in the scope of strategic consulting, corporate and crisis PR, B2B cooperation and employer branding.

3. Great Minds sp. z o.o. registered office in Warsaw, ul. Chmielna 21/19, 00-021 Warsaw, Poland KRS 0000973567, NIP 7011089987, REGON 522137321 data controller in the scope of advertising and creative activities, including marketing strategies, digital and social media campaigns, ATL and BTL activities and retail experience.

2. Data Protection Officer

Each Controller has appointed one common Data Protection Officer.

The Data Protection Officer is:

advocate Piotr Matuszewski

e-mail contact: iod@gardenofwords.pl

The Data Protection Officer may be contacted in all matters relating to the processing of personal data and the exercise of rights under the GDPR.

3. Purposes and Legal Bases for Processing

Personal data are processed for the following purposes and on the following legal bases:

Article 6(1)(b) GDPR – for the purpose of concluding and performing contracts and business cooperation
Article 6(1)(c) GDPR – for the purpose of fulfilling legal obligations imposed on the Controllers, in particular those arising from tax and accounting regulations
Article 6(1)(f) GDPR – for the purpose of ongoing communication, responding to inquiries, maintaining B2B relations, marketing of the Controllers’ own services, and establishing, pursuing or defending legal claims

4. Scope of Processed Data

The scope of processed personal data depends on the nature of the relationship and may include in particular:

- name and surname

- contact details, including e-mail address and telephone number

- company name and job position

- data contained in correspondence, inquiries and contractual documents

- other data necessary for the fulfilment of a specific processing purpose

The Controllers do not process special categories of personal data referred to in Article 9 GDPR, unless such processing is required by law or the data subject has given explicit consent.

5. Recipients of Personal Data

Recipients of personal data may include:

entities providing IT, hosting, accounting, legal, consulting or audit services to the Controllers
entities authorized to receive data under applicable law

Personal data are disclosed only to entities that ensure an appropriate level of personal data protection on the basis of concluded agreements or other legal instruments compliant with the GDPR.

6. Data Retention Period

Personal data are stored:

for the duration of the contract and after its termination for the period required by law or until the limitation period for potential claims expires
in the case of correspondence and inquiries, for the period necessary to handle the matter and safeguard the Controllers’ legitimate interests
in other cases, for the duration of the Controllers’ legitimate interest or until an effective objection is raised

7. Rights of Data Subjects

Individuals whose personal data are processed have the following rights:

- the right of access to personal data

- the right to rectification

- the right to erasure

- the right to restriction of processing

- the right to data portability

- the right to object to the processing of personal data

- the right to lodge a complaint with the President of the Personal Data Protection Office (PUODO)

8. Obligation to Provide Data

Providing personal data is voluntary. However, in certain cases it may be necessary to conclude a contract or to achieve a specific purpose. Failure to provide data may make it impossible to establish cooperation or respond to an inquiry.

9. Profiling and Automated Decision-Making

The Controllers do not use automated decision-making, including profiling, within the meaning of Article 22 GDPR.

10. Cookies

Our website may use cookies that identify your browser when using our website so that we know which page to display to you.

Cookies are created by websites that you visit. They facilitate the use of the internet by storing information about browsing activities. Thanks to cookies, websites recognize that you have previously visited them, remember your settings and provide content relevant to your visit.

The cookies used by us relate to the display of website content.

How can you change your cookie settings?

If you do not consent to the use of cookies or wish to limit their use, you may stop using our website or change the settings of your internet browser. You may change your browser settings regarding cookies at any time, in particular to block automatic handling of cookies (in whole or in part).

Please note that limiting or disabling cookies used by us may affect certain functionalities available on our website.

More information on how to change cookie settings can be found in your browser’s menu under the “Help” section.

Detailed information is also available on the following websites:

11. Final Provisions

The Controllers reserve the right to update this Privacy Policy in the event of changes in legal regulations or changes in the manner of processing personal data. The current version of the Privacy Policy is always available on the website.