Effective from July 2024 

Introduction

The Controller of your data is ROCKWOOL Polska Sp. z o.o. in Cigacice, hereafter referred to as “ROCKWOOL Polska”, which is part of the international ROCKWOOL capital group. 

ROCKWOOL Polska is committed to protecting your privacy. The protection of personal data is important to us. We only process your data in compliance with the applicable data protection legislation, in particular the General Data Protection Regulation (“GDPR”). For that reason ROCKWOOL Group has implemented a set of Binding Corporate Rules (“BCRs”), introducing data protection requirements to be complied with by the ROCKWOOL Group worldwide.  

In connection with our business activities we, as data controller, process the personal data of our customers, suppliers, and users of our websites and apps as well as visitors and other third parties as described further in Section C. 

This Privacy Statement will inform you about what personal data we process, how we collect it, the legal basis, the purpose of our processing, and the retention period. Furthermore, we inform you about your rights as a data subject. 

A. The data controller

ROCKWOOL Polska Sp. Z o.o. 

Ul. Kwiatowa 14 

66-131 Cigacice 

Poland  

E-mail: ldpo@rockwool.com  

Company registration number: KRS 0000089825, REGON 970286608. 

B. Contact

If you have any questions about our Privacy Statement and/or our processing of your personal data, please contact our Data Protection Officer: 

Tel.: (+48) 68 38 50 250 

Email: ldpo@rockwool.com  

C. Information on the processing of personal data

Depending on your relationship with companies from the ROCKWOOL Group, we will process different categories of your personal data for various purposesBelow are details of the purposes and means of processing your personal data. 

Who? 

Categories of personal data 

Purposes of processing 

Legal basis 

Retention periods 

Clients and their representatives 

 

 

 

Name, address, telephone number, e-mail, position and place of work, NIP, REGON, PESEL, number and series of identity document. 

Carrying out ordinary customer relations, i.e.: administration of payments, general communication, and management of day-to-day operations following legitimate and fair business practices (including planning, execution and management of cooperation; statistics, analysis). 

In the case of representatives, the data will be processed based on a legitimate interest related to the fulfilment of business relationships and contracts (Article 6(1)(f) of the GDPR). 

Implementation of a contract with an individual (Article 6(1)(b) of the GDPR). 

 

Until the stated purpose has been fulfilled, but no longer than 12 years from the last purchase of our products or services. 

 

 

Providing general customer service and support, including after-sales surveys 

Legitimate interests in ensuring customer satisfaction and improving our products and services (Article 6 (1) (f) of the GDPR). 

To gain customer insights and knowledge of how our products and services are used (e.g., by sending satisfaction surveys or market surveys). 

Consent of the data subject (Article 6(1)(a) of the GDPR). 

Fraud prevention and payment security. 

Legitimate interests in protecting the interests of the company (Article 6 (1) (f) of the GDPR). 

Establishment, protection or enforcement of legal claims. 

Prospective customers and their representatives 

First and last name, address, phone number, e-mail, job title, and place of work. 

Generating business leads – see Part D for more information. 

 

Consent of the data subject (for electronic activities) or legitimate interests in promoting the company and selling our products and services (Article 6(1)(f) of the GDPR). 

Until the customer is won, but no longer than 5 years after the last interaction. 

 

Measuring effectiveness in customer acquisition – see Part D for more information. 

Data subjects consent (for electronic activities) or legitimate interests in measuring the effectiveness of our activities (Article 6(1)(a), (f) of the GDPR). 

Pursuing business leads. 

Taking steps before entering into a contract (Article 6 (1) (b) of the GDPR). 

Suppliers of goods or services and their representatives 

Name, business telephone number, e-mail, position and place of work, NIP1, REGON2, PESEL3, identity document number and series, vehicle registration number, nationality. 

Carrying out ordinary supplier relations, i.e.: administration of payments, general communication, management of day-to-day operations following legitimate and fair business practices (including planning, execution and management of cooperation; performing credit ratings, as well as carrying out statistics, and analyses). 

Performance of the contract (Article 6(1)(b) of the GDPR) – in the case of suppliers who are natural persons.  

Legitimate interest to execute and perform the contract entered into with the supplier, to establish, defend or assert claims (Article 6(1)(f) of the GDPR) 

Until the stated purpose is fulfilled, but no longer than 12 years from the last purchase of products or services. 

To source and locate suppliers. Entering into and implementing the provisions of executed contracts. 

Legitimate interest in fulfilling business needs and conducting regular business activities (Article 6 (1) (f) of the GDPR). 

Visitors to physical locations 

Name, company name, registration number, if applicable, date and time of visit, ID number, results of breathalyser test. 

Ensuring the security of our physical locations, protecting confidential information and preventing and solving crimes at our physical locations. 

Legitimate interest in ensuring safety on premises and protecting employees, visitors, information and property (Article 6 (1) (f) of the GDPR). 

 

Up to 2 years from the date of registration;  

the results of breathalyser tests indicating a state of alcohol consumption or a state of intoxication shall be kept for a period not exceeding one year from the date of their collection. 

 

 

Up to 90 days from the date of registration or as long as necessary in connection with an ongoing case. 

Video surveillance footage including image, date and location of recording, vehicle registration number and model. 

Recipients of marketing communications 

First and last name, salutation, job title, place of work, e-mail and/or phone number. 

 

Distribution of marketing communications. 

Consent to receive marketing information (Article 6(1)(a) of the GDPR). 

Until the marketing consent has been withdrawn. 

Persons using contact forms 

First and last name, e-mail, telephone number, occupation, company, city, country. 

Providing a response. Communicating, at the request of the person who makes contact, the necessary information, including the presentation of an offer. 

Communication for the purposes of marketing, promotion and sale of the company’s products and services, and to provide support. 

If the enquiry concerns the (potential) conclusion of a contract, the legal basis will be taking the steps necessary to enter into a contract or to perform an existing contract (Article 6(1)(b) of the GDPR). 

Consent to provide marketing information (Article 6(1)(a) of the GDPR). If the inquiry does not concern a contract or offer, the legal basis will be our legitimate interest in handling the inquiry (Article 6 (1) (f) of the GDPR). 

Until the contact is completed and then for the period necessary for our record-keeping purposes. 

In the case of data processed based on consent, until the purpose is no longer valid or consent is withdrawn. 

Account users 

First and last name, e-mail address, telephone, occupation, company, address. 

Providing the user with our services on websites or apps. 

Performance of a contract for the provision of electronic services (Article 6 (1) (b) of the GDPR). 

Until the account is closed and then for the period necessary for our record-keeping purposes. 

Communication of commercial and marketing information. 

Consent of the data subject (Article 6(1)(a) of the GDPR). 

Until the consent is withdrawn. 

Management of user accounts created; for security, statistical and analytical purposes 

Legitimate interest in conducting statistics and analyses to improve the user experience (Article 6 (1) (f) of the GDPR). 

Until the account is closed and then for the period necessary for our record-keeping purposes. 

Visitors of social media profiles 

Information publicly available on a user’s profile, including name, gender, marital status, place of work, interests, image and city; whether the user has “liked” or used other reactions on our profile; comments left on our posts; content shared with the company with the intention of interacting; the fact that the user has visited our profile; IP address. 

To improve our products and services, including our social media profiles and pages; 
For statistical and analytical purposes; 
To communicate with users if they engage with our content (comments, reviews, messages); to re-post content that has been shared with us. 

* platform providers may process users’ personal data for their own purposes – please keep in mind this is outside of our control 

Legitimate interest to be able to communicate with users and address marketing communications to users on our social media profiles, as well as our legitimate interest to improve our products and services (Article 6(1)(f) of the GDPR). 

Retention periods are set out by social media platform providers and can be found in their privacy policies: 

X (formerly Twitter): https://twitter.com/pl/privacy 

D. Our marketing and advertising activities

Description 

When? 

Categories of personal data 

Purposes of processing 

Legal basis 

Retention periods 

Cookies, tracking pixels, social media tools and other technologies used by our websites and apps 

When users visit our websites or apps and have consented to the use of cookies or similar technologies. 

IP-address, MAC address, type of browser and devices, a webpage that led the users to the website or app, search terms entered in a search engine which led the user to our website, browsing history, click-behaviour and use and navigation of websites and apps* 

* the categories depend on the consent given in the cookie banner. This can be changed at any time here 

To run marketing activities, especially to facilitate the use of the websites and apps; for service development, statistics, and analysis; to deliver personalised content and search 

Legitimate interests in providing a website and app that works, marketing, developing, and providing statistics, evaluating, promoting and selling our products and services through first-party cookies, (Article 6 (1) (f) of the GDPR). 

Consent for the processing of personal data in relation to marketing cookies and third-party statistical cookies (Article 6 (1) (a) of the GDPR). 

In addition, we always obtain a valid cookie consent with the exemption of strictly necessary cookies and other technologies. 

Personal data obtained through cookies, pixels, similar technologies, and social media tools are deleted as described in the cookie declaration. 

Custom / lookalike audiences on Facebook or platform X 

When the user registers to receive our marketing information and accepts our cookies, pixels or similar technologies, in some cases we will send Facebook (Meta) or X (Twitter) irreversibly encrypted information. 

E-mail address and in some cases, information about the user’s interest in one or more of our products. 

To create audiences for subsequent advertising via Facebook or X. 

Legitimate interest in spreading awareness of our products and services, including to other persons who may have similar interests in our products and services (Article 6 (1) (f) of the GDPR), based on the consent given (Article 6(1)(a) of the GDPR). 

Until the consent is withdrawn. 

The user can change settings in your Facebook account here. 

Instructions on how to change the privacy settings on X are available here. 

Tracking e-mails 

Emails we send for marketing purposes based on consent given or in connection with events to which users have signed up may contain tracking technologies that tell us whether the recipient has received or opened the email or clicked on a link in the email. 

Tracking information about the user’s interaction with our emails. 

To deliver personalised content, analysis, and statistics. 

Consent to this action (Article 6(1)(a) of the GDPR). 

If users have consented to marketing communications: until such consent is withdrawn. 

 

E. Transfer of data between ROCKWOOL Group companies 

Your personal data may be transferred between ROCKWOOL Group companies for the purposes for which they were collected, provided that such transfer is not prohibited or restricted by law The transfer of personal data between ROCKWOOL Group companies (both in Poland and abroad) is carried out on the basis of Binding Corporate Rules (BCRs), approved by the Danish data protection supervisory authority. 

The ROCKWOOL Group structure is presented at ROCKWOOL Group Companies . 

Your personal data may be entrusted to service providers necessary for the fulfilment of our processing purposes indicated above, that is, among others, to: 

  • IT service providers, 
  • Social media suppliers,  
  • Email suppliers,  
  • Hosting suppliers,  
  • Providers of cookie files and similar technologies,  
  • Webinar tool vendors, 
  • Customer learning platform vendors, 
  • Customer support platform vendors, 
  • Customer relation platform vendors, 
  • Website vendors. 
  • Audit firms, 
  • Debt collection companies, 
  • Consulting firms. 

In certain circumstances and under the law, it may be necessary to transfer your personal data also to the following categories of data controllers: 

Controller category 

Type of personal data 

Legal basis 

Public authorities, law enforcement authorities, courts, lawyers, and external auditors 

 Information required by law or relating to the establishment, protection or enforcement of claims. 

Our obligation under the law (Article 6(1)(c) of the GDPR) or our legitimate interests (Article 6(1)(f) of the GDPR). 

Payment processing companies 

Payment information. 

Performance of the contract (Article 6(1)(b) of the GDPR), obligations under the law (Article 6(1)(c) of the GDPR). 

Where consent has been given to the use of cookies or similar technologies for marketing purposes, data may also be shared with other parties, in accordance with our Cookie Policy. 

If we transfer your personal data to recipients (both controllers and processors) whose registered offices are located in a third country for which the European Commission has not adopted an adequacy decision, such transfer shall be made on the basis of the EU-US Privacy Framework (for US-based companies) or the Standard Contractual Clauses approved by the European Commission (for other countries), a copy of which can be obtained by contacting us in the manner set out above (section B). ROCKWOOL commits to have in place the appropriate security measures to safeguard your personal data and our website has security measures in place to protect against the loss, misuse and/or alteration of the personal data under our control. 

Cooperation with social media platform providers 

Facebook, Instagram and LinkedIn 

In the case of Facebook and Instagram (owned by Meta Platforms Ireland Ltd.), ROCKWOOL, together with the social media providers, are joint data controllers for the processing of personal data collected in connection with your interactions with the profiles, including posts made as part of your interactions with our profile pages. When Meta processes your personal data to create target groups (lookalike and custom audiences), it acts as a data processor on our behalf. 

In the case of LinkedIn, we and the platform provider are joint controllers of the data processed for statistical purposes.  

We have entered into agreements with the providers of the LinkedIn, Instagram and Facebook platforms regarding the sharing of data protection tasks. According to these agreements, the entities (such as ROCKWOOL) and the social media providers are each responsible for the tasks associated with the processing undertaken. Information on the division of responsibilities can be found here: 

YouTube 

ROCKWOOL also uses Google tools in relation to the use of YouTube. Accordingly, we share certain information about your interactions, interests, etc. with Google in order to optimise our marketing and services, including our YouTube videos. 

Twitter / platform X 

When uploading custom audiences to platform X (Twitter), the platform provider (X/Twitter) will act as a data processor for ROCKWOOL.  

F. Your rights as data subjects 

  1. Right to access (Article 15 of the GDPR), i.e. right to obtain confirmation whether we process your personal data, including obtaining a copy of the data.  
  2. Right to rectification (Article 16 of the GDPR), i.e. right to receive the rectification of your personal data and completion of incomplete personal data.  
  3. Right to erasure (Article 17 of the GDPR), i.e. the right to erasure of your personal data without undue delay. Please note that this is not an absolute right and certain exceptions apply, e.g. where the legislation requires further processing. 
  4. Right to restriction of processing (Article 18 of the GDPR), i.e. right to restrict further processing of your personal data if one of the conditions specified in Article 18(1) of the GDPR applies.  
  5. Right to data portability (Article 20 of the GDPR), i.e. right to receive your personal data in structured, machine-readable format for your own use or to have it transmitted by us directly to another controller.  
  6. Right to object (Article 21 of the GDPR) gives you the possibility to object to the processing of your personal data whenever the legal basis for such processing is our legitimate interest (Article 6(1)(f) of the GDPR). This is not an absolute right and in some cases, we may not grant your request and at the same time inform you of the reasons. This includes situations where we process your data for direct marketing purposes based on our legitimate interest. 
  7. Right to withdraw consent (Article 7(3) of the GDPR) whenever the processing is based on it. If you withdraw your consent, we will cease to process your personal data for the purposes for which the consent was given.  The withdrawal of consent does not affect the lawfulness of the processing of your data carried out on the basis of consent prior to its withdrawal. 
  8. Right to lodge a complaint (Article 77 of the GDPR) with a competent supervisory authority, if you deem we have infringed your right to personal data protection.  

Prezes Urzędu Ochrony Danych Osobowych

ul. Stawki 2

00-193 Warszawa 

Polska 

kancelaria@uodo.gov.pl, infolinia: 606-950-000  

G. Changes to our Privacy Statement

Due to technical developments, the emergence of new data processing activities and/or changes in legal requirements, we reserve the right to amend the Privacy Statement. Insofar as changes to the Privacy Statement are deemed to be material and significant, you will be informed of them on our website. An up-to-date version of this Privacy Statement will always be available at www.rockwool.com/group/privacy-statement .