MODICA cares about privacy. It is important to us that everyone feels confident about how we treat personal data. We always collect and process personal data responsibly and according to applicable law.

The MODICA’ Privacy Policy gives information about what rights you have regarding your personal data in relation to MODICA. 

If you are an employee of MODICA, our Employee Privacy Policy applies to MODICA’s processing of your personal data for these purposes. Such privacy policy is provided to you in connection with your employment.

1 WHO IS RESPONSIBLE FOR YOUR PERSONAL DATA?

“Us”, “we”, “our” means MODICA P.S.A. registered with the Polish Companies Register under the registration number  REGON: 523449198, KRS 0000998265. Modica main office islocated at Zurawia 45 street, Warsaw, Poland. We are legally responsible for the personal data that we hold and process, as described in this Privacy Policy.

2 HOW DO WE COLLECT PERSONAL DATA?

2.1 We may collect personal data when you contact us, visit our website, apply for employment within our organization and during a recruitment process, or when we are fulfilling an assignment or service provided by you or a company that you represent.

2.2 In some cases, we may collect personal data from different companies or public authorities, e.g. to verify any of the personal data that you have provided us in a recruitment process. We may also collect personal data in such a process if we chose to contact a reference person named by you. When we are collecting personal data from different companies or public authorities, this is always done in accordance with applicable law.

3 WHAT PERSONAL DATA DO WE PROCESS?

3.1 The personal data that we process is listed below, although not in an exhaustive way. To exemplify we may process the following data:

1. contact information – such as name, postal address, e-mail address, phone number, title and workplace information.

2. identification information – such as national ID-number, citizenship, passport data, work permit, employee ID, tax registration number and photo.

3. We will never ask you for the special categories of data – any personal data that you may provide us which constitutes “special categories” of personal data according to EU Regulation 2016/679 (“GDPR”), including e.g. data revealing religious, political or philosophical beliefs, trade union membership, or data concerning health, biometric information, sex life or sexual orientation. If you provide us with such data it is on a strictly voluntary basis and based on your explicit consent.

4. Recruitment-related data – such as educational background, previous work experience information, qualifications and work history, language skills (e.g. CV), professional information contained in social media, geographic location preferences, hobbies, interview notes and communication information (e.g. e-mail conversations with you in connection with the recruitment process).

5.  We may also collect and process personal data about how you are using our website. Such personal data is collected through cookies and similar technologies that collect information. 

4 WHY DO WE PROCESS PERSONAL DATA, WHAT PERSONAL DATA DO WE PROCESS AND WHAT IS THE LEGAL BASIS FOR THE PROCESSING?

4.1 Processing in order to fulfill our contractual obligations

4.1.1 Administration

1. Purpose of the processing: Administer the relationship between, and interact with you in your capacity as a representative for any of our clients, suppliers or other third parties, (“Partners”). Fulfill our obligations as a party in an agreement.

2. Personal data we may process: Contact information and any information that may be provided in connection with such business activity.

3. Legal basis for the processing
   MODICA has a legitimate interest in being able to conduct its business effectively. As a contact person for the Partner there is a relevant and appropriate relationship between you as a data subject and MODICA as the controller. We make sure that the processing for this purpose is necessary for fulfilling our legitimate interest and that our interest outweighs your fundamental rights and freedoms and your interest in not having your personal data processed for this purpose. In relation to information about Partners who are private individuals, the legal basis for processing personal data is performance of the obligations which govern the agreement.
   
   

4.1.2 Transfer of personal data

1. Purpose of the processing: Transfer your personal data to Partners, please see more information in section 5 below.

2. Personal data we may process: Contact- and identification information.

3. Legal basis for the processing: MODICA may have legal obligations to share data with authorities. We make sure that the processing for this purpose is necessary for fulfilling our legitimate interest and that our interest outweighs your fundamental rights and freedoms and your interest in not having your personal data processed for this purpose.
   
   

4.2 Provide information and marketing

4.2.1 Information

1. Purpose of the processing: Send you information regarding changes in our general terms or our policies.

2. Personal data we may process: Contact information.

3. Legal basis for the processing: We make sure that the processing for this purpose is necessary for fulfilling our legitimate interest and that our interest outweighs your fundamental rights and freedoms and your interest in not having your personal data processed for this purpose. Since this information is vital in our business relationship you cannot refuse to accept this information unless you wish for us to stop processing your personal data.
   
   

4.3 Compliance and protection of our legal rights

4.3.1 Personal data

1. Purpose of the processing: Protect our business and your personal data from fraud or other illegal activities.

2. Personal data we may process: Contact- and identification information.

3. Legal basis for the processing: The processing is strictly necessary for the purposes of preventing fraud and other forms of misuse. We make sure that the processing for this purpose is necessary for fulfilling our legitimate interest, and that our interest outweighs your fundamental rights and freedoms and your interest in not having your personal data processed for this purpose.
   
   

4.3.2 Legal claims

1. Purpose of the processing: Protect MODICA from legal claims and enforce our legal rights.

2. Personal data we may process: All of the personal data categories mentioned in section 3.

3. Legal basis for the processing: We make sure that the processing for this purpose is necessary for fulfilling our legitimate interest and that our interest outweighs your fundamental rights and freedoms and your interest in not having your personal data processed for this purpose.
   
   

4.3.3 Legal obligations

1. Purpose of the processing: Comply with legal obligations.

2. Personal data we may process: Contact- and identification information, special categories of data and payment information.
   
   

4.4 Recruitment

4.4.1 Administration & Evaluation $ Communication

1. Purpose of the processing
   Administer your job application, evaluate your qualifications and suitability for a certain position that you have applied for within our organization and communicate with you in connection with your application.

2. Personal data we may process: Contact information, identification information and recruitment-related data. To the extent that you, on a voluntary basis, provide us with personal data that belongs to the category “special categories of data”, the processing may also include this type of personal data.

3. Legal basis for the processing: We make sure that the processing for this purpose is necessary for fulfilling our legitimate interest and that our interest outweighs your fundamental rights and freedoms and your interest in not having your personal data processed for this purpose.

5 DO WE SHARE PERSONAL DATA WITH ANY THIRD PARTIES?

5.1 We do not transfer or disclose your personal data in any other ways than those described in this Privacy Policy unless we have informed you of such disclosure beforehand and, when necessary, you have given your consent to such disclosure.

5.2 Your information is not transferred or shared with any third party for their marketing or business purposes without your consent.

5.3 We may share your personal data with our Partners such as collaborators when necessary to perform their job and to suppliers that provide services to us or provide services on our behalf. The suppliers we use are solely entitled to process your personal data in order to provide us with their offered service and support, and we enter into agreements with each supplier that stipulates that they may only process your personal data in accordance with our given instructions.

Our Partners in IT services are located in EU.

5.4 A person, legal entity or company that is processing personal data on our behalf is called a “processor”. In some cases, we act as a processor when we are processing your personal data and not as a controller. In these cases, we may not be able to provide you with your personal data directly at your request. Instead we will first need to inform the controller who originally collected your personal data that you have requested such access. When we are acting as a processor you should therefore turn directly to the controller in order to gain access to your personal data.

5.5 In some cases, we may be forced to disclose your personal data to a public authority or a public court in order to comply with a governmental decision or a legal obligation. This may be the case in a legal proceeding, when it is necessary to disclose such information due to national security, when it is necessary to prevent physical harm or economic failure, or when there are ongoing investigations regarding fraud, illegal services or economic crimes.

5.6 We reserve the right to, at a reconstruction, liquidation, merger, acquisitions, business restructuring or the like, transfer your personal data to any relevant third parties.

6 WHERE DO WE PROCESS YOU PERSONAL DATA?

6.1 We do not transfer your personal data outside the EU or the European Economic Area (EEA) unless you have given your consent to the transfer, or there is sufficient protection in accordance with applicable law to make such a transfer. 

7 YOUR LEGAL RIGHTS

7.1 You have certain legal rights regarding the personal data that we process about you. These legal rights are listed below.

1. a) right to be informed – you have the right to be informed about how we process your information. We fulfill this obligation through this Privacy Policy and by answering your questions.

2. right to access – you may request a copy of your personal data if you would like to know what personal data we process about you.

3. right to rectification – if any of the personal data that we process about you is inaccurate or incomplete, you can contact us and ask for it to be rectified or completed.

4. right to withdraw consent – you have a right to withdraw a consent that you have given to us that allows us to process your personal data for a specific purpose. If you withdraw your consent, we will stop processing your personal data for that purpose. However, your right to withdraw your consent does not affect our right to process the personal data that we have collected before your withdrawal if such personal data is necessary in order for us to fulfill a given specific purpose or a legal obligation.

5. right to object – if you believe that we are processing your personal data wrongfully, you have a right to object to such processing. You may object to a processing that is based on our legitimate interest. If you object, we will make an assessment on whether we have the right to continue to process your personal data or not. If you have given your consent to the processing of your personal data, kindly observe that you cannot object to such processing. Instead you need to withdraw your consent as stated above. Furthermore, you can always object to us using your data for direct marketing.

6. right to restriction – you have a right to request that we shall restrict the processing of your personal data if you find that your data, or our processing of it, is wrongful in relation to applicable law. If we receive such a request, we will restrict our processing to merely storing your personal data until we have made an assessment of our right to process your personal data. If we wish to process your personal data in any other way than storing it, before the assessment is completed, we will need your consent for such processing.

7. right to erasure – you have a right to request that we shall cease all processing of your personal data and erase it from our systems. Unless we have a legal right to continue to process your personal data in order to fulfill a legal obligation or a legitimate interest, we will fulfill your request. Any personal data that we are allowed to continue to process in accordance with applicable law, we will erase when the legal obligation or legitimate interest has been fulfilled.

8. right to data portability – you have a right to demand that we transfer your personal data to another controller. We can help you with the transfer if your personal data is stored digitally and the transfer is technically possible. If we cannot make the transfer, you will nevertheless receive a copy of your personal data that you then can transfer on your own.

8 HOW LONG DO WE PROCESS YOUR PERSONAL DATA?

8.1 We ensure that your personal data is not stored for longer periods of time than necessary in order to fulfill the purpose for which it was collected, unless otherwise required or permitted by applicable law. Personal data will be deleted or duly anonymized when no longer required.

8.2 If the time that we will store your personal data can be explicitly stated when your data is collected, or if there are circumstances that will shorten or prolong the time described in this section 8.1, you will receive additional information from us.

9  HOW DO WE PROTECT YOUR PERSONAL DATA?

9.1 We protect your personal data by communicating our guidelines and policies on integrity, security and protection to all our employees and to our whole organization. We also maintain and take the technical and organizational measures that we find appropriate in order to protect your personal data and to comply with applicable law.

10 COOKIES 

10.1 We use cookies on our website www.modica.bio

11 CONTACT DETAILS

11.1 If you have any questions regarding our Privacy Policy or the processing of your personal data, or if you want to lodge a complaint, please contact us at info@MODICA.bio and we will handle your request as soon as possible.