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Clause in case of categorical refusal – the “Robinson List”

The “Robinson List” includes phone numbers of persons who demand permanent cessation of initiating telephone interviews and of any future telephone contacts. Thanks to the “Robinson List”, at each automatic generation of a new sample of phone numbers for a survey or purchase of a database, before commencing the survey, it is verified whether a given phone number is not on the “Robinson List”. If it is, this number is removed from the specific survey sample so that no call is made to a person who has refused future contact.

1. CONTROLLER

The controller of your personal data is 4P Research Mix Sp. z o.o., Puławska 12A/5, 02‑566 Warsaw, NIP 521‑32‑24‑826, KRS 0000148637 (the “Controller” or the “Company”). The Controller can be contacted as follows:

  • a) by post at the address indicated above,
  • b) by e‑mail: mail@grupa4p.pl
  • c) by phone: +48 22 565 27 50

2. DATA PROTECTION OFFICER

For matters related to the processing of your personal data and the rights connected therewith, you can contact the Data Protection Officer at iod@grupa4p.pl or in writing at the Controller’s registered address indicated in point 1 above.

3. CATEGORIES OF PERSONAL DATA

The Controller will process your personal data to the extent of the phone number.

4. PURPOSES AND LEGAL BASIS OF PROCESSING

Your data will be processed in order to:

  • a) maintain a register of phone numbers belonging to persons who refused to participate in the survey or any future telephone contact by the personal data Controller – legal basis: Art. 6(1)(f) GDPR – the Controller’s legitimate interest consisting in respecting the rights of data subjects (persons who did not consent to future telephone contact),
  • b) establish, pursue or defend potential claims – legal basis: Art. 6(1)(f) GDPR – the Controller’s legitimate interest.

5. RETENTION PERIOD

Your personal data will be processed until an objection to the processing of personal data is lodged or a request for deletion is made, but no longer than for a period of 2 years from the date the phone number is entered on the Robinson List.

The above periods may be extended where processing is necessary to establish, pursue or defend potential claims.

6. SOURCE OF PERSONAL DATA

Your personal data were obtained:

  • a) using the random digit dialing method (random generation of phone numbers),
  • b) by purchasing a database,
  • c) by entrustment from a client for whom we carry out a survey. In such a situation, we become the Controller of your personal data from the day your phone number is entered on the Robinson List.

7. RECIPIENTS OF DATA

Your personal data may be disclosed to:

  • a) subcontractors and entities providing services to the Controller (including, among others, IT service providers and technical support) – on the basis of appropriate data processing agreements and in accordance with the Controller’s instructions,
  • b) public authorities and entities performing public tasks or acting on behalf of public authorities, to the extent and for purposes resulting from generally applicable law.

8. YOUR RIGHTS

The Controller enables you to exercise the following rights:

  • a) access to the content of data – you are entitled to obtain access to your personal data and obtain their copy. In addition, you have the right to obtain information in particular on the purpose of processing, categories of data processed, information about recipients, the planned retention period, and your rights,
  • b) objection to the processing of personal data – at any time you may object to our processing of your personal data if we process them on the basis of our legitimate interest. After an objection is lodged, we will not be able to process personal data based on the aforementioned grounds for processing unless we demonstrate compelling legitimate grounds for processing that override your interests, rights and freedoms or grounds for the establishment, exercise and defence of claims,
  • c) erasure of data – if your personal data are no longer necessary for the purpose for which they were collected or you lodge an objection to processing and at the same time there are no overriding, legitimate interests on our part, as well as where you consider that we process your data unlawfully, you have the right to demand their deletion in whole or in part. However, this right does not apply to data insofar as they are necessary to establish, exercise or defend our claims or to fulfil our legal obligation to process or store them resulting from applicable law,
  • d) lodging a complaint with the supervisory authority – if you consider that we process your personal data unlawfully, you have the right to lodge a complaint with the national supervisory authority, which is currently the President of the Personal Data Protection Office (UODO).

In the event of exercising the above rights, please send your request to the address indicated in point 1 or 2 of this clause. We also inform you that the above rights are not absolute and will not apply in every case of our processing of your personal data.