Information Clause for the users of the Metropolitan Transport Authority (ZTM) page on Facebook
At the ZTM we pay special attention to the respect for privacy and personal data protection of ZTM pages users in social media on the Internet. Our actions result from provisions of the 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, hereinafter: GDPR).
You can find below the information, how we process the personal data of the Metropolitan Transport Authority (ZTM Info) fanpage users on Facebook, provided by the Facebook Inc. with the registered office in the United States, 1601 S. California Ave, Palo Alto, CA 94304.
1. Who processes your personal data?
The Metropolitan Transport Authority (ZTM), with the registered office in Katowice, 21A Barbary street, email address: firstname.lastname@example.org, website: http://bip.metropoliaztm.pl, is your personal data Controller.
2. What personal data do we process?
We process the information that allows to identify you. In the case of the ZTM Info page on Facebook we process:
- Your name and surname or nick, which you use on Facebook (this data is not verified by us to confirm, whether it is true),
- your user’s identifier (individual number assigned to your account),
- identification data, within the scope you decided to disclose in the presentation on your private Facebook profile,
- image saved on you profile photo,
- other identification data, which you decide to publish in relation to the ZTM Info page on Facebook, e.g. our profile likes, comments or statements, as well as when you mention the ZTM Info page (tag it) in a post or comment,
- other identification data, which you decide to publish on the ZTM Info page on Facebook in posts, comments, via reactions to our contents or other activities on the ZTM Info page,
- identification information, which you decide to publish in the content of correspondence carried out by you on Messenger (we can learn then your e-mail address or phone number),
- anonymous statistical data related to the ZTM Info page users on Facebook, available through the ‘Facebook Insights’ functionality, which is collected in accordance with the general terms and conditions of Facebook use, approved by you, gathered due to text files (referred to as ‘cookies’), each of them contains an unrepeatable user code, allowing to link with the connection data of users registered on Facebook, which is collected and processed at the moment of opening the ZTM Info page on Facebook.
3. Who should be contacted concerning your personal data?
With respect to your personal data you can contact the ZTM employees, who are responsible for running the ZTM Info page. You can write to us via Messenger. Also the Data Protection Officer is available at the e-mail address: email@example.com.
4. For what purpose and based on what grounds we process the personal data?
We process your personal data, because we use tools provided by the Facebook, Inc. in the form of a fanpage, Messenger communicator and other analytical instruments. The amount of your personal data, processed by us, results from your activity on Facebook.
Your data is processed to:
- run the ZTM Info page on Facebook pursuant to terms and conditions determined by the Facebook, Inc. and inform through it about the ZTM activities, promote events organised or supported by the ZTM, build and maintain community related to the ZTM brand, and to communicate via available Facebook functionalities (e.g. comments, posts, Messenger), which is our legitimate interest (basis: GDPR Art. 6 para 1e and f);
- potentially determine, pursue or protect against claims (basis: GDPR Art. 6 para 1e and f), e.g. if your comment or post is offensive or if another user offends you by his/her post and you address us for help;
- carry out analyses related to functioning, popularity, the way of fanpage use, to be capable of fanpage improvement (basis: GDPR Art. 6 para 1f).
In addition, we can process your data based on separately provided consent (basis: GDPR Art. 6 para 1a). We will inform you then in a separate message. We can also process your data due to legal requirements, which we shall comply with (basis: GDPR Art. 6 para 1c).
5. How long do we process your personal data?
Your personal data will be processed during a period necessary to carry out the aforementioned purposes of processing, that is:
- personal data (name, surname, nick, image, user’s identifier), which you have made public and the identification data, that was published by you in comments or reactions to the contents on the ZTM Info page on Facebook or in the form of other activities related to the ZTM Info page on Facebook, will be processed until you remove it or till closing of the ZTM Info page on Facebook,
- personal data, which we have in messages sent via Messenger, will be stored till the answer to the question or till closing of the ZTM Info page on Facebook,
- personal data gathered by the service owner, the Facebook, Inc., i.e. the history of posts or the history of activity on Messenger, is subject to retention based on rules specified in the service regulations,
- data processed based on legitimate interest of the Controller will be processed till effective lodging of an objection or till this interest ceases,
- statistical data of page visitors available by means of the ‘Facebook Insights’ function will be processed during the period of this data availability on Facebook, equal to 2 years.
6. To whom can we make your personal data available and why?
We can provide your data to recipients, who based on our order perform tasks related to the ZTM and its area promotion, e.g. employees, ZTM partners, or other entities or individuals.
Moreover, we can provide your personal data to public authorities, that is various offices, and entities performing public tasks, or acting to the order of public authorities, within the scope and for purposes resulting from universally effective legislation, that is when we are obliged to provide it.
The personal data may be also provided by the Facebook Ireland Limited, that is a subsidiary, to the owner of the community portal, Facebook, Inc. 1601 S. California Ave, Palo Alto, CA 94304, United States, according to rules specified and described at the address https://www.facebook.com/about/privacy.
To the other users of the ZTM Info page on Facebook and other Facebook users, excluding the identification data by means of Messenger, provided that you have agreed to that.
7. What else is worth to know?
Because we process your personal data, you are entitled to a number of rights related to your privacy protection.
- You can ask us, whether we have your data, and what data it is. You can also request a copy of your data.
- You can request to rectify, correct, or erase your data.
- You can request restriction of your personal data processing.
- If you have previously agreed to process your personal data, you can withdraw the consent at any time.
- You can also lodge a complaint with the President of the Personal Data Protection Office, if you reckon that we process your personal data not in compliance with the legislation.
- The information on planned changes, that we present on Facebook, is also made available on the website rj.metropoliaztm.pl. However, you will not find there the information on current difficulties.
- Your personal data will not be used by us for automated decision-making or profiling, referred to in GPRD Art. 22.
8. To what threats we want to draw your attention?
The Facebook, Inc., within the carried out activity, transfers your personal data outside the European Economic Area (EEA). Therefore running the page on Facebook we do not have full control of what identification information the service owner holds and how he processes it. This results from the fact that in the United States there is a lower level of personal data protection than in the European Union. The GPRD is not effective in the USA and it is not certain that your rights will be respected. Who has what impact on your privacy?
1. Using the ZTM Info page on Facebook you must be aware that you do not have a full guarantee to obtain access to your personal data, to rectify it or to erase it.
2. You have limited possibilities to sue before United States courts your rights in the field of personal data protection. The legislation there does not guarantee European Union citizens the right for effective legal protection before the court and a fair trial (Art. 47 of the Charter of Fundamental Rights of the European Union).
What can you do?
If you do not agree to transfer your personal data processed via the ZTM Info page on Facebook, you can give up following our Facebook page and stop starting relationships with us via its use, including contacts via Messenger, or placing comments, using the likes.