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    Legal information

    Legal information.

    Group definition, data flow between entities and the scope of mutual services within Zwyrtek Group.

    1

    Definition of Zwyrtek Group

    The name “Zwyrtek Group” refers to entities personally or financially related, operating within the group and providing integrated legal, tax, advisory and outsourcing services. These entities cooperate to deliver end-to-end support to business and individual clients.

    Zwyrtek Group consists of the following entities:

    • Zwyrtek Tax & Legal sp.k.
    • Zwyrtek Business Services sp. z o.o.
    • Zwyrtek Advisory sp. z o.o.
    • Zwyrtek Digital sp. z o.o.
    • Michał Zwyrtek
    2

    Data processing and data flow within the Group

    Within Zwyrtek Group, personal data may be both shared and entrusted for processing between individual entities.

    2.1

    Legal basis for sharing data

    Personal data may be shared within the group based on:

    • internal administrative purposes of joint controllers;
    • explicit consent of the data subject;
    • applicable laws (e.g. the Act on Statutory Auditors).

    Pursuant to Recital 48 of the GDPR, controllers that are part of a group of undertakings have a legitimate interest in transmitting personal data within the group for internal administrative purposes. This applies in particular to data of clients and employees.

    2.2

    Employee and contractor data

    For personnel data, internal administrative purposes include activities related to the employment or cooperation relationship, such as:

    • recruitment and professional development;
    • task allocation in interdisciplinary projects;
    • internal statistics and reporting;
    • joint training and events.

    Controllers ensure that the group’s interests do not infringe on the rights and freedoms of data subjects.

    3

    Scope of mutual services within the Group

    The entities forming Zwyrtek Group provide each other with mutual support services, enabling process optimisation and higher service quality. The scope includes in particular:

    • Infrastructuresubletting of office space and joint office maintenance.
    • OperationsIT services, leasing of computer and office equipment.
    • Back-officefinance, accounting, HR & payroll support and recruitment.
    • Compliancelegal advisory and personal data protection support.
    • Marketingpromotional and communication activities for the Zwyrtek Group brand.
    4

    Transparency towards Clients

    Client data may be transferred between group entities solely for the proper performance of contracted services. Detailed information on the purposes, legal basis and rules of data processing for each service is provided in the dedicated information clauses delivered when the cooperation begins.

    5

    Contact

    For any questions regarding the scope of processing, sharing or entrustment of personal data within Zwyrtek Group, please contact our contact point: