GDPR

The title of the document

Privacy Policy of Symmetrical

The purpose of the document

Fulfilling the disclosure requirement resulting from personal data protection regulations

Effective date

Abridged versions (PDF for download)

Background Information

This Privacy Policy constitutes a comprehensive collection of all information on data processing by Symmetrical. It concerns all websites, mobile applications, services and agreements concluded by Symmetrical.

The policy is always available at Symmetrical.ai/gdpr and via Symmetrical’s mobile application. It is also sent to your email address in the course of concluding any agreement with Symmetrical (if the agreement is concluded in writing, a hard copy of the policy may be additionally provided).

The selection menu below allows you to jump to specific chapters of our Privacy Policy.

1.  What personaldata does Symmetrical collect?
2.  What is thepurpose for which Symmetrical processes personal data?
3.  From where doesSymmetrical obtain personal data?
4.  Who will haveaccess to my personal data?
5.  Rights of thedata subject
6.  Data storageperiod
7.  Cookies
8.  Data protectionofficer

You can also use the links above to download the Policy (as a PDF file) or obtain abridged versions of the policy that are dedicated to certain agreements or services.We used our best efforts to write the Policy in a clear, simple and transparent manner. We limited the number of references within the document and references to legal regulations. Nevertheless, a read-through the entire policy will reveal unavoidable repetitions.

The policy applies to all our websites, applications, services and agreements, that is to all the personal data that we process. Therefore, the Policy is available to all our employees, collaborators, contractors and clients across Europe. The type of relationship between us or the method in which it was established (in writing, via the website, via the mobile application, over the phone, by email, in the course of a promotional campaign, on a conference, or via a social networking site) is of no relevance. For this reason, the Policy contains information that may not apply to your specific situation. In order to ensure that the policy is legible, we made the main text of the Policy a collection of universal information and principles, and any derogations from that standard are clearly marked and their origin is explained.

Please note that Symmetrical is not a single entity. Symmetrical is a group that currently comprises three enterprises, each of which provides a different scope of services, concludes different agreements, and processes different personal data, but for the sake of simplicity, we refer to them as Symmetrical, We or Our. If there is a need to distinguish information about a certain enterprise from our group, it will be clearly marked.

What enterprises belong to the Symmetrical group?

SYMMETRICAL.AI Limited., with its registered office in Suite 1, 3rd Floor 11 – 12 St. James’s Square, London, United Kingdom, SW1Y 4LB, entered in the Companies House Register under number 11843660.
Clarification
Symmetrical.ai is a British company that owns Symmetrical Labs and Symmetrical Financials; it predominantly serves a holding function (supports the management of the Symmetrical group).SYMMETRICAL LABS SP. Z O.O., with its registered office in Warsaw on ul. Rozbrat 6/17, 00-451 Warsaw, entered in the register of entrepreneurs of the National Court Register maintained by the District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division of the National Court Register, under KRS no. 0000747407, NIP (tax ID) 7010850471, share capital: PLN 300,000 paid in full.
Clarification
Symmetrical Labs is a Polish technology company which delivers IT solutions required for the proper functioning of salary financing services.SYMMETRICAL FINANCIALS SP. Z O.O., with its registered office in Warsaw on ul. Rozbrat 6/17, 00-451 Warsaw, entered in the register of entrepreneurs of the National Court Register maintained by the District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division of the National Court Register, under KRS no. 0000775925, NIP (tax ID) 7010911511, share capital: PLN 200,000 paid in full.
Clarification
Symmetrical Financials is a Polish financial company which is a credit intermediary registered with the Polish Financial Supervision Authority and a lending institution that provides financial products as a part of salary financing services.

What personal data does Symmetrical collect?

Summary:
We process different data from different sources depending on the services you use, the agreements you conclude and on whether you contact us in writing, online or, e.g., over the phone. Much of that data is provided by you personally, e.g., when filling in an agreement or registering in the mobile application. Data may also be provided by your employer or ordering party. We may compile data about the device through which you use our services or communicate with us, or data obtained via your device, e.g., about your location. If necessary, we also obtain data from data providers, e.g., from economic information bureaus.By data, we mean personal data, i.e., all information through which we are able to identify you and all data connected to that information. Such data includes, e.g., a given name and surname, phone number, email address and residential address.

We only ask for data that we consider necessary to achieve the purpose for which we collect them. If in any situation the provision of data is not necessary, you will be informed of that fact and you will decide whether to provide such data or not. Please note that your refusal to provide additional data may affect the terms and conditions and the manner in which a given service is provided or a concluded agreement is performed.

What is the purpose for which Symmetrical processes personal data?

Summary:
We process data for the purposes of performing the agreement, fulfilling our obligations resulting from legal regulations, for marketing purposes, quality testing, or even asserting claims/defending against claims. Naturally, in doing so we follow personal data protection laws. Some of those purposes do not require your consent (as the processing of your data is, for instance, simply required for the provision of the ordered service, which makes it unnecessary for us to collect your additional consent, and we will contact you via all the available communication channels, i.e., we will contact you by traditional post, email, text message, over the phone or using messages in the Mobile Application), and if such consent is required, we will not only ask you for permission to process your data, but we will also try to ask for your preferences, e.g., as to the method of contacting you when accomplishing a given objective (e.g., you may consent to receiving marketing information via email, but not over the phone).

From where does Symmetrical obtain personal data?

Summary:
We obtain your data using various methods. Firstly, we try to obtain your data directly from you, which gives you the knowledge about what and when is disclosed to us. Data can also be obtained from your employer or ordering party, which, in particular in the course of providing salary financing services, allows us to confirm your data at a reliable source, avoid unnecessary bureaucracy, and relieves you from having to provide us with numerous certificates or declarations documenting, e.g., the employment with a given employer or your earnings. We also use the services of third-party data providers, e.g., economic information bureaus. Please bear in mind that we exchange data within the Symmetrical group, in particular in the scope necessary to perform the administrative functions (e.g., handling correspondence, accounting and financial reporting).

Who will have access to my personal data?

Summary:
Your data are transferred only when such a transfer is permitted by legal regulations. However, it should be emphasized that sometimes such a transfer does not require your consent. A data transfer might be based directly on legal regulations, a need to perform an agreement, or be conducted under a data processing agreement that we concluded, which enables us to provide the data to our subcontractors. If the data are entrusted to our subcontractors, they process your data only within a scope and for a purpose that we strictly defined. We strive to select only proven and trustworthy providers, and these are mostly IT service providers, accountants and couriers. We also transfer the data from Symmetrical Labs to the providers of financial and insurance products, if you express willingness to use such services in the Application. We co-operate only with subcontractors who observe the highest security standards with regard to the data, just like ourselves, with infrastructure located within the European Economic Area (EEA) or the U.K.

Rights of the data subject

Summary:
You have all the basic rights that arise from regulations on personal data protection. If you wish to exercise your rights and, e.g., gain access to your data, withdraw your consent for the processing of your data for a particular purpose, or if you want to request that your data be deleted, all you need to do is contact us by phone, email or in writing. We also use our best efforts to enable the management of personal data via the mobile application. We hope that functionalities allowing, e.g., the management of data processing consents will be available soon.

Data storage period

Summary:
We store personal data for as long as necessary to achieve the objectives listed in this Policy.

Cookies

Information on cookies isprovided in a separate document available at https://symmetrical.ai/cookies-policy/

Data protection officer

You can contact our data protection officer via email at gdpr@symmetrical.ai or by writing to:
Symmetrical – Data Protection Officer
Bartosz Kapuściński
Rozbrat 6/1700-451 Warsaw
Poland
Moreover, you are always entitled to lodge a complaint concerning personal data to the President of the Personal Data Protection Office (www.uodo.gov.pl), i.e., the Polish authority supervising the observance of legal regulations on personal data protection.