Data Controller

The Data Controller of your personal data is Benhauer sp. z o.o., based in Cracow, Stanisława Klimeckiego 4, entered in the Register of Businesses maintained by Division XI of the National Court Register of the District Court for Kraków-Center in Kraków under KRS number 0000523346, REGON number 122334666, and NIP number 6762447754 (hereinafter referred to as “Benhauer” or “the Controller”).

GDPR - Regulation (EU) No. 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural people with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).


Categories of data subjects whose data are processed by the Controller

The Controller processes personal data, in particular, of the following categories of data subjects:

Categories of data subjects Types of processed personal data
Job candidates personal data referred to in provisions (in particular in labor law); personal data received based on the freely given consent of data subjects
Contractors, their representatives, people conducting agreements, and contact people personal data referred to in provisions needed to register and provide invoices (e.g., company name, company register number, address); personal data necessary to maintain business relations (name, surname, phone number, email address, job position)
Customers using the trial, demo, or free version of the product name, surname, company name, country, company email address, phone number, company website address
Newsletter subscribers email address
People who have consented to receiving commercial and marketing information via electronic communication or using telecommunications devices and automatic calling systems name, surname, company name, country, company email address, phone number, company website address, job position
People who signed up for training or webinars name, surname, company name, country, company email address, phone number, company website address, job position
SALESmanago website users user identification number, user preferences and activity on the SALESmanago site, other information necessary to ensure the operation of the site
People sending questions to the Controller via phone calls, email, or forms name, surname, company name, company email address, phone number


Principles of personal data processing

Job candidates

Purposes and legal basis of personal data processing:
The Controller will process the personal data of job candidates for the following purposes

  • to take steps at the request of the data subject prior to entering into a contract (Article 6(1)(b) GDPR);

  • to fulfill legal obligations to which the Controller is subject, arising from legal provisions, in particular from labor law (article 6(1)(c) GDPR);

  • for personal data that are beyond the range referred to in Article 22^1 of the Labor Code, on the basis of freely given consent - only if such consent was given (Article 6(1)(a) GDPR).

Source of data: In certain cases, personal data may be provided by third parties, in particular recruitment agencies with which we cooperate as part of ongoing recruitment processes.

Processing period: Personal data will be processed for 6 months from the end of the recruitment process. Personal data processed on the basis of given consent will be processed until the consent is withdrawn or until the purpose for which the data was obtained is achieved. In the case of given consent for processing personal data for future recruitment processes, personal data will be processed for up to 12 months.

Recipients of the personal data: The Controller may disclose the personal data of the contractors to entities authorized by law. Entities supporting the Controller, including IT service providers, may also have access to the personal data of job candidates based on agreements conducted with the Controller.

Voluntary/obligatory nature of providing personal data: Providing personal data referred to in Article 21^1 of the Labour code is obligatory. Providing other personal data is voluntary, however necessary to conclude an agreement with the Controller. Providing personal data processed on the basis of given consent is voluntary and not giving them does not make any negative consequences.

Transfers of personal data to third countries or international organisations: The Controller does not transfer personal data to third countries or international organizations.

Decision based solely on automated processing/profiling: The Controller does not make decisions based solely on automated processing, including profiling (concerning the purposes of the data processing described above).

Contractors, their representatives, people conducting agreements, and contact people

Purposes and legal basis of personal data processing:
The Controller will process the personal data of contractors who are natural people for the following purposes:

  • to perform an agreement between the contractors and the Controller or to take action at the request of the contractors before the conclusion of the contract (Article 6(1)(b) of the GDPR);

  • to fulfill the legal obligations incumbent on the Controller, arising in particular from tax and accounting legislation (Article 6(1)(c) of the GDPR);

  • for the purpose of improving the functionality of the SALESmanago platform and the services provided through it, including optimizing features, ensuring service continuity, and enhancing customer support quality, which constitutes the legitimate interest of the Controller (Article 6(1)(f) of the GDPR);

  • processing of personal data for statistical and analytical purposes, including, among others, analysing how users interact with the platform, measuring the effectiveness of activities, and generating aggregate reports to support product and service development, which constitutes the legitimate interest of the Controller (Article 6(1)(f) of the GDPR).

  • to pursue or defend against claims, which is the legitimate interest of the Controller (Article 6(1)(f) of the GDPR).

Purposes and legal basis of personal data processing:
The Controller will process the personal data of the contractor’s representatives, people conducting agreements, and contact people for the following purposes:

  • to maintain business contacts, which is the legitimate interest of the Controller (Article 6(1)(f) of the GDPR);

  • to fulfill the legal obligations incumbent on the Controller, arising in particular from tax and accounting legislation (Article 6(1)(c) of the GDPR);

  • for the purpose of improving the functionality of the SALESmanago platform and the services provided through it, including optimizing features, ensuring service continuity, and enhancing customer support quality, which constitutes the legitimate interest of the Controller (Article 6(1)(f) of the GDPR);

  • processing of personal data for statistical and analytical purposes, including, among others, analysing how users interact with the platform, measuring the effectiveness of activities, and generating aggregate reports to support product and service development, which constitutes the legitimate interest of the Controller (Article 6(1)(f) of the GDPR).

  • to pursue or defend against claims, which is the legitimate interest of the Controller (Article 6(1)(f) of the GDPR).

Processing period: The personal data of the contractors shall be processed for the period required by law or until the expiration of the limitation period for any claims, depending on which of these events occurs later. Personal data processed for contact purposes will be processed for the duration of the business relationship.

Recipients of the personal data: The Controller may disclose personal data to entities authorized by law. Entities supporting the Controller, including IT service providers, may also have access to the personal data based on agreements conducted with the Controller.

Voluntary/obligatory nature of providing personal data:: Providing personal data is voluntary; however, it is necessary to conclude an agreement with the Controller.

Transfers of personal data to third countries or international organizations: Personal data will be processed in tools/systems provided by entities supporting the Controller that are based in or process data outside the European Economic Area. In such cases, personal data is transferred on the basis of standard contractual clauses approved by the European Commission or a decision of the European Commission stating an adequate level of protection in a given country, e.g. on the basis of the EU-US Data Protection Framework.

Decisions based solely on automated processing/profiling: The Controller does not make decisions based solely on automated processing, including profiling (concerning the purposes of the data processing described above).

Customers using the trial, demo, or free version of the product

Purposes and legal basis of personal data processing:
The Controller will process the personal data of customers using the trial, demo or free version for the following purposes:

  • to perform the contract concluded by accepting the Terms of Service, the subject of which is to grant access to the trial, demo, or free version of the product offered by the Controller (Article 6(1)(b) of the GDPR);

  • for the purpose of improving the functionality of the SALESmanago platform and the services provided through it, including optimizing features, ensuring service continuity, and enhancing customer support quality, which constitutes the legitimate interest of the Controller (Article 6(1)(f) of the GDPR);

  • processing of personal data for statistical and analytical purposes, including, among others, analysing how users interact with the platform, measuring the effectiveness of activities, and generating aggregate reports to support product and service development, which constitutes the legitimate interest of the Controller (Article 6(1)(f) of the GDPR).

  • to pursue or defend against claims, which is the legitimate interest of the Controller (Article 6(1)(f) of the GDPR).

Processing period: Personal data will be processed for the period necessary to perform the contract for the use of the trial version of the product, and then for the period of limitation of any claims. If a paid version of the product is purchased, the trial account will be converted into an account with full access to the purchased services. In this case, personal data will be stored for the period required under applicable law or for the period of limitation of any claims, whichever occurs later.

Recipients of the personal data: The Controller may disclose the personal data of the contractors to entities authorized by the law. Entities supporting the Controller, including IT service providers, may also have access to the personal data based on agreements conducted with the Controller.

Voluntary/obligatory nature of providing data: Providing personal data is voluntary but necessary to obtain access to the trial, demo, or free version of the product.

Transfers of personal data to third countries or international organizations: Personal data will be processed in tools/systems provided by the entities supporting the Controller that are based in or process data outside the European Economic Area. In such cases, personal data is transferred on the basis of standard contractual clauses approved by the European Commission or a decision of the European Commission stating an adequate level of protection in a given country, e.g. on the basis of the EU-US Data Protection Framework.

Decisions based solely on automated processing/profiling: The Controller does not make decisions based solely on automated processing, including profiling (concerning the purposes of the data processing described above).

Newsletter subscribers

Purposes and legal basis for personal data processing:
The Controller will process the personal data of newsletter subscribers for the following purposes:

  • to conduct marketing activities, including personalized marketing content regarding the Controller and its products, which is the Controller’s legitimate interest (Article 6(1)(f) of the GDPR).

Processing period:Personal data will be processed until consent to send commercial information to the indicated e-mail address is withdrawn. Consent can be withdrawn by sending an email to dpo@salesmanago.com.

Recipients of the personal data: The Controller may disclose the personal data of contractors to entities authorized by law. Entities supporting the Controller, including IT service providers, may also have access to the personal data of contractors based on agreements conducted with the Controller.

Voluntary/obligatory nature of providing personal data: Providing personal data is voluntary; however, it is necessary to receive commercial information as part of the newsletter service.

Transfers of personal data to third countries or international organizations: Personal data will be processed in tools/systems provided by entities supporting the Controller that are based in or process data outside the European Economic Area. In such cases, personal data is transferred on the basis of standard contractual clauses approved by the European Commission or a decision of the European Commission stating an adequate level of protection in a given country, e.g. on the basis of the EU-US Data Protection Framework.

Decisions based solely on automated processing/profiling: The Controller does not make decisions based solely on automated processing, including profiling (concerning the purposes of the data processing described above).

People who have consented to receiving commercial and marketing information via electronic communication or using telecommunications devices and automatic calling systems

Purposes and legal basis for personal data processing:
The Controller will process the personal data of people who have consented to receiving commercial and marketing information for the following purposes:

  • to conduct direct marketing or send commercial and marketing information using the provided email address or telephone number, which is the legitimate interest of the Controller (Article 6(1)(f) of the GDPR);

  • to demonstrate that the Controller is acting legally, which is the legitimate interest of the Controller (Article 6(1)(f) of the GDPR);

  • to pursue or defend against claims, which is the legitimate interest of the Controller (Article 6(1)(f) of the GDPR).

Source of data: In some cases, personal data may have been obtained from publicly available sources, such as professional social networking sites (e.g. LinkedIn) or B2B lead generation tools that allow the identification of contact details based on a provided email address or company domain.

In such cases, we only process data obtained in compliance with applicable laws and use it solely for the purpose of sending commercial information, provided that valid legal grounds exist – such as your prior consent or the legitimate interest of the controller.

Processing period: Personal data will be processed until consent to receive commercial information to the indicated email address or phone number is withdrawn. Consent can be withdrawn by sending an email to dpo@salesmanago.com.

Recipients of the personal data: The Controller may disclose the personal data of contractors to entities authorized by law. Entities supporting the Controller, including IT service providers and selling partners, may also have access to the personal data of contractors based on agreements conducted with the Controller.

Voluntary/obligatory nature of providing data: Providing personal data is voluntary, and not providing it does not result in any negative consequences.

Transfers of personal data to third countries or international organizations: Personal data will be processed in tools/systems provided by entities supporting the Controller that are based in or process data outside the European Economic Area. In such cases, personal data is transferred on the basis of standard contractual clauses approved by the European Commission or a decision of the European Commission stating an adequate level of protection in a given country, e.g. on the basis of the EU-US Data Protection Framework.

Decisions based solely on automated processing/profiling: The Controller does not make decisions based solely on automated processing, including profiling (concerning the purposes of the data processing described above).

SALESmanago website users

Purposes and legal basis for personal data processing:
The Controller will process the SALESmanago website users for the following purposes:

  • To conduct analytical and statistical measurements on the Controller's website, including site traffic and to customize the site to the user's preferences (in accordance with consent to the use of cookies on the device), which is a legitimate interest of the Controller (Article 6(1)(f) of the GDPR);

  • to provide basic functionality of the website, which is a legitimate interest of the Administrator (Article 6(1)(f) of the GDPR).

Processing period: Personal data will be processed for the lifetime of individual cookies or until you withdraw your consent to the use and install of cookies on your device. You can withdraw your consent by clicking the “Manage cookies” button at the bottom of the page.

Recipients of the personal data: The Controller may disclose the personal data of contractors to entities authorized by law. Entities supporting the Controller, including IT service providers and selling partners, may also have access to the personal data of contractors based on agreements conducted with the Controller.

Voluntary/obligatory nature of providing data: Providing personal data is voluntary, and not providing it does not result in any negative consequences.

Transfers of personal data to third countries or international organizations: Personal data will be processed in tools/systems provided by entities supporting the Controller that are based in or process data outside the European Economic Area. In such cases, personal data is transferred on the basis of standard contractual clauses approved by the European Commission or a decision of the European Commission stating an adequate level of protection in a given country, e.g. on the basis of the EU-US Data Protection Framework.

Decisions based solely on automated processing/profiling: The Controller does not make decisions based solely on automated processing, including profiling (concerning the purposes of the data processing described above).

People who signed up for training or webinars

Purposes and legal basis of personal data processing:
The Controller will process the personal data of people who signed up for training or webinars for the following purposes:

  • to perform the contract concluded by accepting the Terms of Service, the subject of which is the organization of training or webinars, including sending notifications regarding the event and verification of attendance at the event itself (Article 6(1)(b) of the GDPR).

Processing period: Personal data will be processed for the period necessary for the execution of the contract and thereafter for the period of limitation of possible claims.

Recipients of the personal data: The Controller may disclose the personal data to entities authorized by law. Entities supporting the Controller, including IT service providers, may also have access to the personal data based on agreements conducted with the Controller.

Voluntary/obligatory nature of providing data: Providing personal data is voluntary, but necessary to participate in the organized event.

Transfers of personal data to third countries or international organizations: Personal data will be processed in tools/systems provided by entities supporting the Controller that are based in or process data outside the European Economic Area. In such cases, personal data is transferred on the basis of standard contractual clauses approved by the European Commission or a decision of the European Commission stating an adequate level of protection in a given country, e.g. on the basis of the EU-US Data Protection Framework.

Decisions based solely on automated processing/profiling: The Controller does not make decisions based solely on automated processing, including profiling (concerning the purposes of the data processing described above).

People sending questions to the Controller via phone calls, email, or forms

Purposes and legal basis of personal data processing:
The Controller will process the personal data of people sending questions for the following purposes:

  • to answer the question sent, conduct electronic correspondence, and carry out actions taken at the request, which is a legitimate goal of the Controller (Article 6(1)(f) of the GDPR).

Processing period: Personal data will be processed for the duration of the email correspondence or for answering questions asked by phone, and then for the period of archiving email correspondence, unless consent is obtained to send commercial and marketing information or a business relationship is established. In such cases, the storage period will be consistent with the data storage period for "People who have consented to the receiving of commercial and marketing information via electronic communication or using telecommunications devices and automatic selecting systems" or “Contractors, their representatives, people conducting agreements, and contact people”.

Recipients of the personal data: The Controller may disclose the personal data to entities authorized by law. Entities supporting the Controller, including IT service providers, may also have access to the personal data based on agreements conducted with the Controller.

Voluntary/obligatory nature of providing data: Providing personal data is voluntary; however, it is necessary to obtain an answer to the question asked.

Transfers of personal data to third countries or international organizations: The Controller does not transfer personal data to third countries to third countries or international organizations.

Decisions based solely on automated processing/profiling: The Controller does not make decisions based solely on automated processing, including profiling (concerning the purposes of the data processing described above).


Rights of the data subjects

You have the right, as applicable, to:

  • request access to your personal data, rectification, deletion, and limitation of processing. If your personal data is processed by automated means on the basis of your consent or a contract, you also have the right to transfer your personal data;

  • withdraw your consent at any time if the data was processed on the basis of this consent. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

  • object to the processing of your personal data when the data is processed on the basis of the Controller's legitimate interest.


Right to lodge a complaint

You also have the right to lodge a complaint with the supervisory body:
PUODO - President of the Office for Personal Data Protection, ul. Stawki 2, 00-193 Warszawa, e-mail: kancelaria@uodo.gov.


The Controller’s contact details

The Data Controller:
Benhauer sp. z o.o. based in Cracow
(SALESmanago operator)
Stanisława Klimeckiego 4
30-705 Kraków
e-mail: rodo@salesmanago.com

Data Protection Officer:
Marcin Lis
e-mail: dpo@salesmanago.com


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