Information Clause for Whistleblowers

Does the Ethics Line collect my personal data?

Your personal data will be processed only if you submit a non-anonymous report. If you choose to file an anonymous report, the Ethics Line will not collect any data that identifies you. Providing personal data is not mandatory. You may independently choose whether to file an anonymous report or one that includes identifying information.

The data collected will include the information you provide in your report and the data gathered during subsequent investigations. In addition to identifying information, we will collect data on the reported event, which allows us to determine the circumstances of the alleged violation and to take appropriate action. Any data that is not relevant to the report will be deleted.

Your data will be co-administered by Innova Capital Sp. z o.o (Rondo ONZ 1, 00-384 Warsaw) and STX Next S.A. (Mostowa 38, 61-854 Poznań). These companies use a shared channel for handling reports and have an agreement in place regarding its administration.
Further information can be obtained via email at administrator@stxnext.pl.

The legal basis for data processing is the statutory right of the Companies to process data in connection with the proceedings triggered by the notification of a suspected legal violation or external procedure (art. 8 sec. 4 of the Whistleblower Protection Act). Data provided that are not necessary to establish the circumstances of the incident will be deleted. Data will be collected solely to determine the circumstances of the event and to potentially undertake subsequent actions.

If necessary, data may be disclosed to relevant state authorities in connection with ongoing proceedings. Apart from this, data will not be disclosed to other recipients. Furthermore, data will not, under any circumstances, be transferred to third countries (including entities associated with STX in such countries). Identifying data will not be disclosed to other individuals unless you provide explicit consent.

Data will be stored in the system for 3 years from the end of the year in which actions associated with the report are concluded, after which they will be deleted. If any information irrelevant to the proceedings is provided, it will be deleted within 14 days of collection.

You have the right to request access to, rectification of, deletion of, or restriction on the processing of personal data concerning yourself, as well as the right to data portability.
The co-administering companies jointly perform the above responsibilities. To exercise your rights, use the contact information provided in this form or through the Ethics Line platform.
You have the right to lodge a complaint with the President of the Data Protection Office if you believe your rights have been violated.