Privacy Policy for the SUUS Tracker App
In accordance with 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 (hereinafter the "Regulation"), we inform you that:
Personal Data Controller
The controller of the personal data is ROHLIG SUUS Logistics S.A. (hereinafter referred to as the "Company" or the "Controller") with its registered office in Warsaw (02-235), Równoległa 4A.
Data Protection Officer
The Controller has appointed a Data Protection Officer.
The e-mail address of the Data Protection Officer is: [email protected].
Purposes and legal basis of personal data processing
- Your personal data will be processed in order to track the location of your shipments, and the legal basis for the processing is Article 6(1)(f) of the Regulation, as it is necessary to pursue the Company's legitimate interest, namely to manage the quality of services provided by its subcontractors and to provide recipients with the service of tracking the delivery of the ordered shipment.
- Your personal data will also be processed in order to maintain contact with the carrier on whose behalf you are making the delivery, through you, as this is necessary for the Company's legitimate interest in maintaining ongoing contact with the Company's contractors.
Data processed in connection with the installation of the App
The App will be able to access the following cell phone functions:
- taking photographs and video - for the purpose of documenting transportation incidents and damage,
- device location information - for the purpose of monitoring the location of transported shipments,
- photos, multimedia and files on the device - for the purpose of attaching documentation of transportation incidents and damages,
- making and managing telephone calls - for the purpose of facilitating driver contact with the dispatcher,
- audio recording - for the purpose of facilitating voice documentation of transportation incidents and damage.
The legal basis for the processing of such personal data is Article 6.1.a of the Regulation, i.e. the user's consent expressed in accordance with the provisions of Article 173.1 of the Telecommunications Law of 16 July 2004.
Recipients of personal data
Your data may be transferred to:
- Customers requesting services (for tracking services).
- ROHLIG SUUS Group companies with regard to the performance of a forwarding service.
- Subcontractors operating and maintaining the information and communication systems used by the Company.
- Advisory and audit firms and law firms with which the Company cooperates.
- Customs processors in countries of transit and destination.
Transfer of personal data to a third country or international organization
In the event that the contract you are executing involves the performance of a service by you to or by a third country, your personal data will be transferred to that country for the performance of the contract due to the applicability of the exceptions indicated in Article 49(1)(b-e) of the Regulation, that is:
b) 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 request of the data subject.
c) 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.
d) The transfer is necessary for compelling reasons of public interest.
e) The transfer is necessary for the establishment, investigation or protection of claims.
or standard contractual clauses for the transfer of personal data from the Community to third countries (controller-tocontroller transfers), where signed. The clauses in question are available on the website www.suus.com in the Privacy Policy (chapter VII, item 2.).
Personal data retention period
Your data will be used for the period of performance of the service and thereafter for the period of limitation of claims related to its performance and the duration of legal and tax obligations imposed on the Company (as a rule, this will be 5 years, counting from the beginning of the year following the fiscal year in which the deadline for payment of tax related to the provided service expired).
Rights of the data subject
Under the terms of the Regulation and subject to the limitations indicated therein, you have the right to:
- Request access, rectification, erasure or restriction of processing of your personal data from the controller.
- Object to further processing of personal data.
- Transfer personal data.
- Withdraw consent to the processing of personal data at any time, without affecting the lawfulness of processing carried out on the basis of consent before its withdrawal.
- Make a complaint to the President of the Office for Personal Data Protection, 2 Stawki Street, 00-193 Warsaw.
Information on data submission and data source
Providing your personal data is voluntary, but it is a condition for the proper implementation of the contract concluded between the Company and the carrier on behalf of which you carry out transport, and refusal to provide them will be associated with the need to change the driver carrying out the transport.
Data not collected directly from you is obtained from the carrier on whose behalf you are making the transport.
Information about automated decision-making, including profiling
There will be no automated decision-making, including profiling, in connection with the processing of your personal data; however, the data obtained from the App will be used to assess the quality of services for domestic groupage transport, based on indicators of timeliness of the services provided by the carriers.
Personal data processing notice for users of the SUUS Tracker App [PDF]