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Full Privacy Notice of JDC Poland

Full Privacy Notice of JDC Poland

 

This Privacy Notice (“Notice”) will provide you with information on the data processing activities of Fundacja Joint Distribution Committee Poland.

 

The Data Controller:

Fundacja Joint Distribution Committee Poland located at 00-021 Warszawa, ul. Chmielna 9a (“JDC” or “we”) telephone: 22 6521754, e-mail: biuro@jccwarszawa.pl will be the responsible controller of your personal data.

 

The Categories of Personal Data We Process:

We may process the following of your relevant personal data collected from you during your application and participation in JDC programs and in the course of your interactions with us:

  • Basic personal information, including your name, birth city and country, date of birth, previous first and last names, address, ID numbers, e-mail, and phone number.
  • Demographic information, including gender, education, profession, occupation, and marital status.
  • Financial information such as income level and bank account number.
  • Data concerning health: including information regarding your medical history and any current medical conditions.
  • Religious affiliation data, including your participation in movements, events, organizations relative to the Jewish culture. 
  • Photographs, video recordings and audio recordings of your voice, image, simulated likeness, and of other personal characteristics.

 

The Purposes of the Data Processing:

The purposes for which we collect and use your personal data and the relevant data categories we use for the relevant purposes are set out below:

Why We Collect and Use Personal Data:

Personal Data Categories

Legal Basis

Registration and participation in JDC programs and activities;

Basic personal information

Demographic information

Financial information

Religious affiliation data

Data concerning health

Contract

Legal Obligation

Legal Claims

Legitimate Activities

Communication with you and providing to you newsletter services;

Basic personal information

Religious affiliation data

Consent

Legitimate Activities

Providing social services, personal assistance and grants to you;

Basic personal information,

Demographic information

Financial information

Religious affiliation data

Data concerning health

Contract

Legal Obligation

Legitimate Activities

Carrying on, managing and administering our respective operations effectively and properly;

Basic personal information

Religious affiliation data

Legitimate Interests

Legitimate Activities

Reporting about grants to donors;

Basic personal information

Religious affiliation data

Consent

Legitimate Interests

Legitimate Activities

Publication of photo, image video and audio recordings for general promotional and fundraising purposes;

Basic personal information

Photographs, video recordings and audio recordings

Religious affiliation data

Consent

Legitimate Activities

Compliance with accounting and taxation obligations relative to grants;

Basic personal information

Demographic information

Financial information

Legal Obligation

Comply with corporate financial responsibilities, requests and legal demands; establishing, making or defending legal claims.

Basic personal information

Financial information

Religious affiliation data

Data concerning health

Legal Obligation

Legal Claims

Legitimate Activities

 

Legal Bases for Data Processing

The legal grounds we are most likely to rely on for processing data in relation to you are outlined below:

  • Contract[1]: we rely on this legal basis if our data processing is necessary for performance of a contract with you or to take steps at your request to enter into a contract. This covers carrying out our contractual duties and exercising our contractual rights, including the registration and participation in JDC programs and activities or complying with grant requirements if you apply for a grant. If you do not provide the necessary information, your participation in the relevant programs might be delayed or be impossible.
  • Legal obligation[2]: we process data if necessary to comply with our legal and regulatory obligations, such as, for example, to comply with tax reporting and accounting data retention obligations.
  • Legitimate Interests[3]: we rely on legitimate interest if processing is necessary for our or a third party’s legitimate purposes. We, or a third party, have legitimate interests in carrying on, managing and administering our respective operations effectively and properly, and, in connection with those interests, processing your data. Your data will not be processed on this basis if our or a third party’s interests are overridden by your own interests, rights and freedoms.
  • Consent[4]: We may process data if and to the extent you have given specific consent to the processing of your data. We ask for your consent in order to send newsletters and similar communications to you; or we ask for your consent so that we may use and publish your photo, image video and audio recordings for general promotional and fundraising purposes of JDC. We may also ask you for your explicit consent for processing special categories of data, such as Religious Data or Data concerning health. The provision of personal data is voluntary. If we have relied on consent as grounds for processing, you may withdraw your consent at any time – though, if you do so, that will not affect the lawfulness of our actions prior to you withdrawal of consent.

 

We will only process special categories of personal data about you if one or more of the grounds for processing such personal data applies. The activities of our foundation serve charitable purposes; therefore, we may process information about your religious affiliation, such as your participation in movements, events, or organizations relative to the Jewish culture, to the extent data processing relates to persons who have regular contact with us. The additional legal grounds we are most likely to rely on for processing sensitive personal data in relation to you are outlined below:

  • Consent[5]: You have given specific consent to the processing of your religious affiliation data and personal data concerning health. If we have relied on consent as grounds for processing, you may withdraw consent at any time – though, if you do so, that will not affect the lawfulness of our actions prior to your withdrawal of consent.
  • Legal claims[6]: Processing is necessary for the purpose of establishing, exercising or defending legal claims. Those could be legal claims made by ourselves or you or by others, including claims relating to grants.
  • Legitimate Activities[7]we, as a foundation with religious aim, process your religious affiliation data and personal data concerning health in the course of our legitimate activities on condition that the processing relates solely to you as a member or former member of JDC or to you as a person who have regular contact with us in connection with our purposes and that such personal data are not disclosed outside JDC without your consent.

 

Recipients of Personal Data

We may transfer your personal data to third parties for the following reasons:

  • Within the JDC Group: personal data may be transferred to The American Jewish Joint Distribution Committee, Inc. headquarters in New York, located at 220 East 42nd Street, Suite 400, New York, NY 10017. In each case, the transfer is for purposes of carrying on, managing and administering our respective operations effectively and properly; to administer JDC programs, communicate with donors, monitor and ensure compliance with applicable internal procedures (e.g., corporate financial responsibilities), and to respond to and comply with any grant requirements and legal demands. In addition, in the event that our foundation is closed and a new JDC entity is established or if our operations and/or employees are transferred in whole or in part to a new JDC entity that provides services to you, your personal information may be transferred to the new JDC entity prior to the transaction or after the transaction, subject to any rights provided by applicable law, including under the laws of the jurisdiction in which the other entity is located.
  • Donors and/or partnering agencies, including UJA-Federation of New York; The Jewish Federations of North America and their Network Communities (for more information on JFNA’s Network Communities, please see https://jewishfederations.org/network-communities) and Polish government or local authorities. In each case, the transfer is for the purpose of grant administration;[NS1] 
  • With certain third parties: including banks, donors, independent external advisors (e.g, auditors, lawyers), in particular to administer and provide payments, communicate with you and third parties, and respond to and comply with official requests and legal demands.
  • Vendors: we may, in the course of the operation of JDC programs, utilize the services of various data processors and external service providers to handle and process your personal data for specific purposes, on behalf of and in accordance with our instructions. The data processors may store your personal data in protected centralized databases, with limited access, in printed or in electronic form. Electronic databases may only be managed by specially authorized administrators and said databases will be accessible only to such authorized persons. Personal data may be made available to such vendors to be used for the purposes of the particular system or service, and subject to the terms of the data processing agreement(s) between JDC and the relevant vendor. The data processors will process the personal data not longer than the period of the term of the data processing contract concluded with them.

 

International Data Transfers:

JDC may transfer your personal data, in connection with the processing purposes and disclosures identified above, to its parent company, The American Jewish Joint Distribution Committee, Inc. (“JDC, Inc.”), to service providers, to suppliers and external advisers in a territory, such as the United States, that may not provide a level of protection to personal data equivalent to that provided by your home country. In such cases, we will ensure that the personal data is subject to measures that provide an adequate level of protection as is provided by data privacy laws in the EU (such as the EU General Data Protection Regulation; GDPR). Please contact us via e-mail at biuro@jccwarszawa.pl if you would like to receive from us a copy of these measures that secure the adequacy of personal data transfers abroad. Please note that such data transfers may be associated with certain risks, particularly that, in the country of the data recipient, unauthorized third parties may also have unreasonable access to said data and you may not be able to exercise the rights of the data subject and/ or your right to object against acts that may harm your Personal Data and your right to privacy. If you would like to know more about how we protect your personal information when it is transferred outside the EEA, please contact our Data Protection Officer at jdc-dpo@jdc.org.

 

Duration of Data Processing:

Your personal data will not be kept in a form that allows you to be identified for any longer than is reasonably considered necessary by us for achieving the purposes for which it was collected or processed or as required by applicable laws related to data retention periods. Your personal data will, in any case, be retained for the duration of your participation in the JDC programs, as well as thereafter, as long as there are statutory retention obligations or potential claims resulting from your participation are not yet time-barred. A statutory data retention obligation of at least five years applies to personal data in accounting documents, including contracts, invoices, communication and business correspondence. However, access to such personal data will then be highly restricted. The personal data will be removed from our records or properly anonymized when it is no longer needed.

 

Your Rights:

  1. 1.       Right of access

You have the right to obtain from us confirmation as to whether or not personal data concerning you is processed, and, where that is the case, to request access to the personal data. The access information right includes, among others, the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipient to whom the personal data have been or will be disclosed.  You may have the right to obtain one copy of the personal data undergoing processing. If you request additional copies , we may charge you a reasonable fee based on administrative costs.

 

  1. 2.       Right to rectification

You have the right to obtain from us the rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you may have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

 

  1. 3.       Right to erasure (right to be forgotten)

Under certain circumstances, you have the right to obtain from us the erasure of personal data concerning you and we may be obliged to erase such personal data.

 

  1. 4.       Right to restriction of processing

Under certain circumstances, you have the right to obtain from us restriction of processing your personal data. In this case, the relevant data will be marked and may be processed by us only for certain purposes.

 

  1. 5.       Right to data portability

Under certain circumstances, you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit those data to another entity without hindrance from us.

 

  1. 6.       Right to object and rights relating to automated decision-making

You have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data, including profiling, by us and we can be required to cease processing your personal data. If you have a right to object and you exercise this right, your personal data will no longer be processed for such purposes by us. Exercising this right will not incur any costs. Such right to object may not exist, in particular, if the processing of your personal data is necessary to take steps prior to entering into a contract or to perform a contract already concluded.

 

Furthermore, under certain circumstances, in case of automated individual decision-making, you have the right to obtain human intervention, to express your point of view and to contest the decision.

 

If your data processing is based on consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent before its withdrawal. Moreover, if your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. In this case your, personal data will no longer be processed for such purposes by us.

 

Right to Complaint and Legal Remedies

You also have the right to lodge a complaint with the competent data protection supervisory authority. If you believe that your rights have been infringed, you may contact the Polish Personal Data Office (ul. Stawki 2, 00-193 Warsaw; telephone: +48 22 531 03 00, telefax: +48 22 531 03 01, e-mail: kancelaria@uodo.gov.pl). You may also turn to courts if your data protection rights have been infringed.

 

Amendment to the Privacy Notice:

We may amend this Notice from time to time in order to comply with our legal obligations and any changes in the data processing activities of your personal data. We will inform you in advance relating to the amendment or review of this Notice in the way you were originally informed of this Notice. You can determine when this was last revised by referring to the "LAST UPDATED" legend at the top of this Notice.

 

How to Contact Us?

If you have any questions related to data processing under this Notice, please contact Fundacja Joint Distribution Committee Poland located at 00-021 Warszawa, ul. Chmielna 9a, telephone: 22 6521754, e-mail: biuro@jccwarszawa.pl.

 

You may also turn to our Data Protection Officer at jdc-dpo@jdc.org.


 



[1] The legal basis lies in Article 6 (1) (b) of the General Data Protection Regulation (Regulation No. 2016/679 of the European Parliament and of the Council) ("GDPR").

[2] The legal basis for this is Article 6 (1) (c) of the GDPR.

[3] The legal basis for this is Article 6 (1) (f) of the GDPR.

[4] The legal basis for this is Article 6 (1) (a) of the GDPR.

[5] The legal basis for this is Article 9 (2) (a) of the GDPR.

[6] The legal basis for this is Article 9 (2) (f) of the GDPR.

[7] The legal basis for this is Article 9 (2) (d) of the GDPR.

 

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