The data controller is DHL Parcel Polska sp. z o.o. with its registered office in Warsaw (address: ul. Osmańska 2, 02-823 Warsaw), hereinafter referred to as "DHL".
Information on the processing of personal data
DHL’s data protection officer
DHL appointed a data protection officer, hereinafter referred to as the "DPO". You can contact the DPO on all matters related to the processing of your personal data and exercising your rights by sending an e-mail to email@example.com.
Purposes and legal basis of data processing, legitimate interest in processing
Below we present all the standard purposes of data processing by DHL associated with DHL’s business.
The detailed purpose of the processing of your data is always communicated by DHL at the time of collecting your data.
Personal data are processed by DHL to complete your order, including to provide you with the additional services ordered, to register, manage and ensure the operation of your customer account (if any) on dhl24.com.pl or other DHL websites, to register, manage and ensure the operation of your account (if any) on efaktura.dhl.parcel.pl, to manage communications in relation to performing services, to respond to interventions, complaints and/or changes in instructions, to send financial and billing information, to manage promotional campaigns, fulfillment of the legal obligation of DHL, to contact you in response to your messages, and for marketing purposes involving offering you the services of DHL and third parties.
We may carry out the processing of your personal data on the following legal basis:
- your contract with DHL to complete your order, including to provide you with the additional services ordered and to fulfil other obligations DHL may have towards you, to manage communications in relation to performing services, to respond to interventions, complaints and/or changes in instructions (under Article 6.1(b) GDPR);
- your contract with DHL to maintain and manage your customer account on DHL’s websites, for example dhl24.com.pl (under Article 6.1(b) GDPR);
- the necessity of processing for the purposes of DHL’s legitimate interests, including preparing a response or dealing with an issue raised in your message sent to DHL’s e-mail address or via a form on DHL’s website (under Article 6.1(f) GDPR);
- the necessity of processing for the purposes of DHL’s legitimate interests involving direct marketing of the services of DHL and third parties (including by preparing a personalised offer on the basis of the estimated number of shipments), of the establishment, exercise of or protection from legal claims, and also of activities necessary for the performance of a contract to which a natural person is not party (under Article 6.1(f) GDPR);
- the legal obligation, in particular related to conveying of specific information to public authorities, including law enforcement authorities, and documenting economic events for tax and accounting purposes, to which DHL is subject (under Article 6.1(c) GDPR).
To whom and where may DHL transfer your data? Who may be a recipient of your data apart from DHL? (information on data recipients)
Besides DHL employees, attorneys and corporate body members, your data may be accessed by persons and entities who ensure the operation, support and maintenance of DHL’s IT systems and solutions.
Moreover, depending on the nature of the matter, DHL may transfer your personal data only to the following entities:
- entities cooperating with DHL and providing services to DHL, including shipping services, and
- DHL’s insurers, and
- entities providing accounting, financial, legal consultancy or tax consultancy services to DHL, and
- public authorities, including courts, at their reasonable request, and
- public authorities, including courts and attorneys, DHL’s insurers and advisors, where necessary to defend DHL against claims or to pursue DHL’s claims, and
- DHL partners, a current full list of which can be found here.
Transfers of data outside the European Economic Area or to international organisations
Your personal data will not be transferred outside the European Economic Area or to international organisations.
How long will DHL store your data? (information on the period for which the data will be stored)
The period for which DHL will store your data depends on the purpose of processing your data by DHL.
Where your data are processed by DHL to perform a contract between you and DHL (e.g. a shipment contract) or to fulfil other obligations towards you by DHL (e.g. to manage a customer account on DHL websites, including dhl24.com.pl), your personal data will be stored by DHL for the period necessary to fulfil DHL’s obligations towards you, for example under a shipment contract (an order), and until the end of the limitation period for any claims that you may have against DHL and that DHL may have against you in connection with such obligations, for example arising from the shipment contract (order), unless it is necessary to store the data for a longer period for tax purposes – in which case deletion will take place immediately upon expiry of the limitation period for the tax liabilities associated with the obligation, for example with the shipment contract (order) (e.g. for accounting purposes related to a given order, your data will be stored for 5 years from the end of the calendar year in which the tax associated with the order became due and payable).
Where your data are processed by DHL because this is necessary for the purposes of DHL’s legitimate interests, your personal data will be stored by DHL for the period necessary to achieve the purposes of such interests, and where the purpose is direct marketing, for as long as the legitimate interests in marketing exist, unless you exercise your right and object to the processing of those data for marketing purposes. In such a case, DHL may store your data for the duration of the legal limitation period for your claims against DHL or for DHL’s claims against you where the processing of those data is necessary for the establishment, exercise of or defence against such claims.
To pursue its legitimate interests including the establishment, exercise of or defence against claims, DHL may store your data for the duration of the legal limitation period for your claims against DHL or for DHL’s claims against you (e.g. the general limitation period for business claims is 3 years and the general limitation period for consumer claims against DHL is 6 years; the above periods of storing personal data may change to reflect amendments to generally applicable laws).
To pursue DHL’s legitimate interests involving responding to your message, question, complaint or suggestion, DHL may store your data for the period necessary to provide a response or to deal with the matter you contacted DHL about; however, DHL may extend that period by the legal limitation period for your claims against DHL or for DHL’s claims against you where the processing of those data is necessary for the establishment, exercise of or defence against such claims.
Moreover, where claims are brought against or by DHL, for example in connection with a shipment contract (order) between you and DHL, your data will be stored no longer than necessary in connection with the relevant proceedings relating to such claims.
Where DHL processes your data on the basis of a legal obligation to which DHL is subject, DHL will store those data for as long as DHL is subject to the legal obligation. Where your data are necessary to document economic events for accounting purposes, your relevant data will be stored by DHL for as long as DHL is legally obliged to hold documents for those events.
Information on your rights
You have many rights arising from the fact that DHL processes your personal data. Below you will find a brief description of them. To exercise those rights or obtain additional information on them, do not hesitate to contact DHL’s DPO by e-mail at firstname.lastname@example.org.
If you submit a request to exercise your rights to DHL, DHL may request, in the event of reasonable doubts concerning your identity, additional information to confirm your identity. DHL will respond to your requests without undue delay – where possible within one month of receipt of the request.
Where DHL demonstrates that your requests are manifestly unfounded or excessive, in particular because of their repetitive character, DHL may either: (a) charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or (b) refuse to act on the request.
Right of access
You have the right to request access to your personal data, including in particular to information about whether DHL processes your personal data and about the scope of data held by DHL, the purposes of the processing of the data and the categories of recipients of the personal data, where possible, about the planned period for which the data will be stored, about your rights in relation to personal data, and about the sources from which DHL obtained your data where they were not collected from you. You also have the right to obtain a copy of the data, with the proviso that the first copy of the data is free of charge and each next copy may result in a reasonable charge taking into account the administrative costs of preparing such a copy of data.
Right to rectification
You have the right to obtain, without undue delay, the rectification of inaccurate personal data and, taking into account the purposes of the processing, to have incomplete data completed.
Right to deletion (‘right to be forgotten’)
You have the right to request the deletion of your data where one of the following grounds applies:
(a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
(b) you effectively objected to the processing;
(c) the personal data have been unlawfully processed;
(d) the personal data have to be deleted for compliance with a legal obligation;
(e) you have withdrawn your consent to the processing of the personal data and the personal data were processed on the basis of your consent and there is no other legal basis for processing them.
However, you may not be allowed to exercise the right to deletion of data where such data are necessary for the establishment, exercise of or defence against claims, among other things.
Right to restriction of processing
You have the right to obtain restriction of processing where one of the following applies: (a) you contest the accuracy of the personal data – for a period enabling verification of the accuracy of those data; (b) the processing is unlawful and you oppose the deletion of the personal data and request the restriction of their use instead; (c) DHL no longer needs the personal data but you require them for the establishment, exercise of or defence against claims; (d) you object – pending verification of whether the legitimate grounds of DHL override those of your objection.
Right to data portability
You have the right to receive the personal data concerning you, which you have provided to DHL, in a structured, commonly used and machine-readable format and have the right to transmit those personal data to another controller without hindrance from DHL, where: (a) the processing is based on your consent or on a contract with you; and at the same time (b) the processing is carried out by automated means. At the same time, you have the right to have the personal data transmitted directly from DHL to another controller, where technically feasible.
Right to object to processing of data
You have the right to object, on grounds relating to your particular situation, at any time to the processing of your data where the processing is based on DHL’s legitimate interests.
Following an objection, DHL shall no longer process your personal data unless it demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise of or defence against legal claims.
Where personal data are processed for direct marketing purposes, you may object at any time to such processing, including profiling, without the need to demonstrate the reasons relating to your particular situation, and DHL will immediately stop such processing.
Right to lodge a complaint with a supervisory authority
You have the right to lodge a complaint with the President of the Office for the Protection of Personal Data if you consider that the processing of your personal data violates relevant laws.
Information on whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as on the lack of obligation to provide data
Any data you provide are provided freely.
Depending on the circumstances under which DHL may obtain your data, providing certain data (marked by DHL as required) may be a requirement necessary to enter into a contract with DHL or a requirement necessary for commencement of the provision of services by DHL, for example for opening a customer account on DHL websites, for example dhl24.com.pl, and have that account managed by DHL.
Giving the name and address of the sender as well as the name and address of the consignee is necessary to order a service. Giving the consignee’s phone number is necessary to use additional services involving text message notification and notification before delivery. Giving full name, address and tax identification number (NIP) may be a statutory requirement and be necessary to prepare documentation for tax purposes.
Where messages or requests are submitted to DHL (e.g. asking for DHL’s offer), providing contact details is not a statutory or contractual requirement or a requirement necessary to enter into a contract; however, providing the data required is necessary to enable DHL to respond.
Information on the consequences of failure to provide data
Depending on the circumstances under which DHL may obtain your data, failure to provide certain information may prevent you from entering into a contract with DHL, placing an order, using additional services, opening and managing your account on DHL websites, for example dhl24.com.pl, receiving accurate tax documents from DHL, receiving an offer from DHL or a response to a message sent to DHL, and lodging a complaint, making an intervention or changing order instructions with DHL.
Information on using data for automated decision-making, including for profiling
Your personal data will not be used for automated decision-making, including for profiling.