Pursuant to art. 13 par. 1 and par. 2 of the General Data Protection Regulation (GDPR) of 27 April 2016 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 (General Data Protection Regulation, RODO) NETHANSA sp. z o.o. informs, as follows.


NETHANSA sp. z o.o. with legal seat in Sopot (Court Register No. 192382, Statistical-ID 639758009, Tax-ID 7792126883) is Controller of personal data concerning CLIPPERRON users, persons interested in this program or such persons’ representatives. Contact in data protection matters by e-mail or by post to NETHANSA sp. z o.o., ul. Armii Krajowej 116/19, 81-824 Sopot.

The purposes of the processing
as well as the legal basis for the processing

NETHANSA sp. z o.o. processes personal data when:
a) the data subject has given consent to the processing of his or her personal data for one or more specific purposes (art. 6 par. 1 a GDPR)
The data subject shall have the right to withdraw his or her consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Prior to giving consent, the data subject shall be informed thereof. It shall be as easy to withdraw as to give consent (art. 7 par. 3 GDPR).
When assessing whether consent is freely given, utmost account shall be taken of whether, inter alia, the performance of a contract, including the provision of a service, is conditional on consent to the processing of personal data that is not necessary for the performance of that contract (art. 7 par. 4 GDPR).
b) processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (art. 6 par. 1 b GDPR)
c) processing is necessary for compliance with a legal obligation to which the controller is subject (art. 6 par. 1 c GDPR)
d) processing is necessary in order to protect the vital interests of the data subject or of another natural person (art. 6 par. 1 d GDPR)
e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller (art. 6 par. 1 e GDPR)
f) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party (art. 6 par. 1 f GDPR),
— in particular for the analyses leading to CLIPPERON software development according users’ needs as well as for building database necessary to determine, to settle or to refute claims (art. 6 par. 1 f GDPR),
except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child (art. 6 par. 1 f GDPR).

Duration of data processing

1. Personal data will only be processed for a specific purpose and to the extent that it takes, as long as necessary:
— during the contract term with NETHANSA sp. z o. o.
— after termination or expiration of this contract until claims from this contract are possible,
— in other cases pending withdrawal of consent to the personal data processing or pending exercise of the right to object.
2. If processing is necessary to fulfil a legal (legislative) obligation, the processing period is determined by law.
Recipients of data
The processed data – due to CLIPPERON software and trademark development – may reasonably be disclosed to the data processors such as NETHANSA-related companies, IT and data protection sub-contractors, accountancy offices, statutory auditors and audit firms, law offices, marketing agencies.
Access, rectification, erasure, restriction of processing,
objection, complaint
The data subject has the right to:
— request from the controller access to…
— rectification, erasure, restriction of processing…
— portability of…
— object to processing…
…personal data concerning the data subject,
— and lodge a complaint with a supervisory authority.

Statutory or contractual requirement

NETHANSA sp. z o. o. shall whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the data subject is obliged to provide the personal data and of the possible consequences of failure to provide such data
Automated decision-making
If automated decision-making is introduced, including profiling (referred to in Article 22 par. 1 and 4 GDPR) NETHANSA sp. z o. o provides the persons concerned with the required information.