TRANSPOR PARTICIPANT ZONE

INFORMATION ON THE PERSONAL DATA PROCESSING OF TRANSPORT PARTICIPANTS

1. Data Controller 

The controller of your personal data processed in connection with the execution of the carriage of cargo shipments is a Polish Raben Group company which performs the contract of carriage, i.e.: 

• Raben Logistics Polska sp. z o.o.;
• Raben Transport sp. z o.o.;
• Fresh Logistics Polska sp. z o.o.;
• Raben East sp. z o.o. 

In certain situations, however, Raben Group companies may jointly control such data, i.e. jointly determine the purposes and means of processing personal data and ensure security of the process. In the context of carriage, joint controlling takes place particularly when there is two or more Raben Group companies which carry out the carriage. 

For more information on joint controllership, including an up-to-date list of Raben Group companies covered by a joint controller agreement and the purposes of processing of data under joint control, please see section V. of the Raben Group Privacy Policy at: polska.raben-group.com/en/privacy-policy-2. 

2. Point of contact 

The Polish companies of Raben Group have appointed a Data Protection Officer who can be contacted regarding the protection of your personal data at the following e-mail address: gdpr@raben-group.com. The Data Protection Officer is also the main contact point for matters relating to the joint controllership of your personal data. 

Notwithstanding the above, please be advised that in the case of joint control, you may also contact each of the Joint Controllers separately regarding the protection of your personal data. For contact details of joint controllers see section V. of the Raben Group Privacy Policy at: polska.raben-group.com/en/privacy-policy-2. 

3. Purposes of processing, legal grounds for processing and categories of data 

For the purposes of carrying out the transport services we can process the following categories of personal data: name and surname, contact details (telephone number and/or email address), place of loading and/or delivery. 

Personal data of transport participants will be processed in the first instance for the purposes of ensuring the correct performance of the carriage agreement and other services, e.g. those provided by toll agencies, or additional services ordered along with the carriage.

With regard to personal data:

• of transport participants – customers, the legal basis for processing is Article 6(1)(b) of the GDPR, i.e. the necessity of data processing for the performance of a contract to which the data subject is party;

• other participants in the transport – i.e. in particular recipients and contact persons in connection with the transport – the legal basis for processing is Article 6(1)(f) of the GDPR, i.e. our legitimate interest, that of the customer and that of the recipient, which is the proper performance of services, in particular the delivery of goods to the final recipient.

Additionally, personal data of transport participants can be processed in pursuit of the legitimate interests of the controller [legal basis: Article 6(1)(f) GDPR)], i.e. in pursuit of the following: 

• ensuring the proper planning of the carriage, 

• ensuring carriage safety,

• exercise of possible claims (by either party) or defence against them, 

• carrying out activities of administrative, technical and business-supporting nature, e.g. ensuring cybersecurity or legal advisory on the company’s internal processes. 

Insofar as the processing of personal data of participants of the transport is necessary to fulfil legal obligations imposed on the data controller by the provisions of generally applicable law, in particular the Polish Transport Law Act, CMR Convention, toll, tax and/or sanction laws, the legal basis for its processing is the Article 6(1)(c) GDPR. 

We also point out that pursuit of the abovementioned objectives may include the usage of AI-based tools (artificial intelligence), yet no automated decisions will be taken with those tools. Your personal data will not be used to further training of language models. 

4. Period of data storage 

Personal data of transport participants will be stored for the period required by law, for the period of limitation of claims related to provided services or up to the date of conclusion of proceedings connected with the provision of those services (depending on which period is longer). 

5. Data recipients and data transfer to third countries 

Your data may be accessed in particular by the carriers acting at our request, toll agencies, and other service providers whose services data controller engages (e.g. IT services providers, legal counsels, auditors, as well as claim adjusters and entities monitoring the progress of orders and carriage safety). 

Personal data may be transferred to data processors established outside the European Economic Area (EEA). 

Countries outside the EEA may not offer the same level of personal data protection as EEA countries. Before personal data are transferred outside the EEA, we will make every effort to ensure that such transfer does not lead to a reduction in the level of your protection guaranteed under the regulations in force in the EEA countries. If personal data are transferred outside the EEA, the transfer will be based on an adequacy decision or on the basis of standard data protection contractual clauses adopted by the European Commission. You may also request additional information (including copies of the implemented safeguards) with regard to the transfer of the data outside the EEA by contacting us as described in point 2 above. 

6. Your rights and automated data processing

The joint control of personal data under the provision of Article 26(1) of the GDPR does not affect the exercise of your rights. As agreed between the Joint Controllers, each Joint Controller is the entity responsible for the processing of personal data in accordance with the GDPR. 

Due to the above, pursuant to the GDPR, you have the right to access your data and to request their rectification or erasure, as well as to restrict the processing and the right to data transfer. If we process your personal data on the basis of a legitimate interest, you have the right to object to the processing. 

At the same time we inform you that you have the right to lodge a complaint with the supervisory authority for personal data processing, which for Polish companies of Raben Group is the President of the Office for Personal Data Protection (PUODO). 

No automated decisions will be taken based on your personal data, including no profiling will be carried out. 

7. Source of data 

Your personal data has been collected from the entity that commissioned us to provide the transport service.

8. Obligation to provide data (applies to transport participants providing their data directly to us, e.g. shippers) 

Providing personal data is voluntary, however necessary for the conclusion of the agreement and in the next stage for its performance.